State of California et al v. Trump et al

Filing 182

MOTION for Partial Summary Judgment and Opposition to Plaintiffs' Motion for Partial Summary Judgment filed by Department of Defense, David Bernhardt, Mark T. Esper, Steven T. Mnuchin, Kirstjen M. Nielsen, Patrick M. Shanahan, Richard V. Spencer, Donald J. Trump, U.S. Department of Homeland Security, U.S. Department of the Interior, U.S. Department of the Treasury, United States of America, Heather Wilson. Responses due by 6/24/2019. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Proposed Order)(Warden, Andrew) (Filed on 6/19/2019) Modified on 6/20/2019 (cpS, COURT STAFF).

EXHIBIT 7

Exhibit A
El Centro 1 Project Area

L E G END

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8

Proposed Barrier Replacement

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98

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28

STATES

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El Cajon
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AREA ENLARGED
WARNING: This document is FOR OFFICIAL USE ONLY (FOUO).
It contains information that may be exempt from public release under
the Freedom of Information Act (5 U.S.C. 552). It is to be controlled,
stored, handled, transmitted, distributed, and disposed of in accordance
with DHS policy relating to FOUO information and is not be released to
the public or other personnel who do not have a valid "need-to-know"
without prior approval of an authorized DHS official.

Map Request 542v15.2

May 1, 2019

Exhibit B
Tucson Project Area

L E G END
Proposed Barrier Replacement
86
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WARNING: This document is FOR OFFICIAL USE ONLY (FOUO).
It contains information that may be exempt from public release under
the Freedom of Information Act (5 U.S.C. 552). It is to be controlled,
stored, handled, transmitted, distributed, and disposed of in accordance
with DHS policy relating to FOUO information and is not be released to
the public or other personnel who do not have a valid "need-to-know"
without prior approval of an authorized DHS official.

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Map Request 542v15.2

May 1, 2019

Tucson Project Area

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Map Request 542v15.2

WARNING: This document is FOR OFFICIAL USE ONLY (FOUO).
It contains information that may be exempt from public release under
the Freedom of Information Act (5 U.S.C. 552). It is to be controlled,
stored, handled, transmitted, distributed, and disposed of in accordance
with DHS policy relating to FOUO information and is not be released to
the public or other personnel who do not have a valid "need-to-know"
without prior approval of an authorized DHS official.

May 1, 2019

Tucson Project Area

L E G END

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Map Request 542v15.2

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4
WARNING: This document is FOR OFFICIAL USE ONLY (FOUO).
It contains information that may be exempt from public release under
the Freedom of Information Act (5 U.S.C. 552). It is to be controlled,
stored, handled, transmitted, distributed, and disposed of in accordance
with DHS policy relating to FOUO information and is not be released to
the public or other personnel who do not have a valid "need-to-know"
without prior approval of an authorized DHS official.

May 1, 2019

Exhibit C

Exhibit C

Exhibit E

00003730
FINAL

ENVIRONMENTAL ASSESSMENT
FOR THE IMPROVEMENT AND CONSTRUCTION, OPERATION, AND
MAINTENANCE OF PROPOSED ALL-WEATHER ROAD
IN THE EL CENTRO STATION AREA OF RESPONSIBILITY
U.S. CUSTOMS AND BORDER PROTECTION, EL CENTRO SECTOR
U.S.U.S. Customsof HomelandProtection
Department and Border Security
Department of Homeland Security
U.S. Customs and Border Protection
Washington, DC
U.S. Border Patrol

FEBRUARY 2013

00003731

00003732

00003733

00003734

00003735

00003736

00003737

00003738

FINAL

ENVIRONMENTAL ASSESSMENT
FOR THE IMPROVEMENT AND CONSTRUCTION, OPERATION, AND
MAINTENANCE OF PROPOSED ALL-WEATHER ROAD
IN THE EL CENTRO STATION AREA OF RESPONSIBILITY
U.S. CUSTOMS AND BORDER PROTECTION, EL CENTRO SECTOR

February 2013

Lead Agency:

Department of Homeland Security
U.S. Customs and Border Protection
Office of Facilities Management and Engineering
EPA West Building
1301 Constitution Ave., NW
Suite B-155
Washington, DC 20004

Cooperating Agency:

U.S. Bureau of Land Management
El Centro Field Office
1661 S. 4th Street
El Centro, CA 92243

Point of Contact:

Mr. John Petrilla
U.S. Customs and Border Protection
Facilities Management and Engineering
Laguna Niguel Facilities Center
24000 Avila Road, Room 5020
Laguna Niguel, CA 92677-3400

00003739

00003740
EXECUTIVE SUMMARY
INTRODUCTION:

The U.S. Border Patrol (USBP) is a law enforcement entity of
U.S. Customs and Border Protection (CBP) within the Department
of Homeland Security (DHS). USBP’s priority mission is to
prevent the entry of terrorists and their weapons of terrorism and
to enforce the laws that protect the U.S. homeland. This is
accomplished by the detection, interdiction, and apprehension of
those who attempt to illegally enter or smuggle any person or
contraband across the sovereign borders of the United States
between the land Ports of Entry. The addition of new agents,
personnel, and resources will enhance the operational capabilities
of USBP.
The existing U.S./Mexico border road in the USBP El Centro’s
Station’s Area of Responsibility (AOR) is impassable. This
creates long drive times for agents to reach patrol areas and limits
their abilities to assist with interdictions and apprehensions. This
Environmental Assessment (EA) was prepared in accordance with
the National Environmental Policy Act (NEPA) and analyzes the
project alternatives and potential impacts on the human and
natural environment from road corridor improvements and
construction.

PURPOSE AND NEED:

The purpose of the Proposed Action is to increase border security
within the USBP El Centro Sector with an ultimate objective of
reducing illegal cross-border activity by providing safer and more
efficient access for USBP agents along the U.S./Mexico border in
the west desert area of the USBP El Centro Station’s AOR and to
BP Hill. The primary need for the Proposed Action is because of
the remoteness of the west desert area and the impassability of the
existing road, which creates long drive times for agents to reach
patrol areas and limits their abilities to assist with interdictions and
apprehensions. An additional need for the Proposed Action is to
provide agents with the infrastructure necessary to carry out
USBP’s mission.

DESCRIPTION OF
PROPOSED ACTION:

The Proposed Action would improve and construct, operate, and
maintain approximately 1.6 miles of all-weather road near the
U.S./Mexico border within USBP El Centro Station’s AOR. The
existing 1.4-mile road that would be improved is west of the AllAmerican Canal and adjacent to and within U.S. Bureau of Land
Management’s (BLM) Yuha Desert Area of Critical
Environmental Concern. The Proposed Action includes
improvements to the existing border road, construction of a new
access road to the top of BP Hill, and required maintenance

West Desert Road EA

Final
February 2013

00003741
ES-2

activities upon completion of the proposed project. The Proposed
Action also includes the construction of a new access road to the
top of BP Hill (0.2 mile in length).
PROPOSED ACTION
AND ALTERNATIVES
CONSIDERED:

One other viable action alternative was identified and considered
during the planning stages of the proposed project. This
alternative would consist of the Proposed Action but with no new
road construction to BP Hill. Instead, only road improvements to
the existing BP Hill access road would be implemented. The No
Action Alternative, which would preclude the construction,
operation, and maintenance of border road, was also evaluated.
Two alternatives were considered but eliminated from further
consideration. The first alternative was to construct a new road
parallel to the U.S./Mexico border within the 60-foot Roosevelt
Reservation. Extensive earth moving and engineering would be
required for this alternative due to the impassability of the entire
road. The other alternative considered but eliminated was to
improve limited areas within the existing border road and BP Hill.
Only improving segments of the road, as proposed in the second
eliminated alternative, would not meet the purpose and need of the
proposed project.

AFFECTED
ENVIRONMENT AND
CONSEQUENCES:

The improvement, construction, operation, and maintenance of 1.6
miles of all-weather road would potentially result in minimal to
moderate impacts, including temporary increased air pollution
from soil disturbance, permanent loss of up to 7.5 acres of
vegetation and wildlife habitat, and minor increases in water use
and ambient noise. No adverse impacts on historic properties or
threatened or endangered species would occur. No residences or
children are found near the project corridor; thus, the road
improvements and construction would have no effect relative to
environmental justice or protection of children issues.

FINDINGS AND
CONCLUSIONS:

No major adverse impacts are anticipated for any resource
analyzed within this document. Therefore, no further analysis or
documentation (i.e., Environmental Impact Statement or
Environmental Impact Report) is warranted. CBP, in
implementing this decision, would employ all practical means to
minimize and mitigate the potential adverse impacts on the human
and biological environment.

West Desert Road EA

Final
February 2013

00003742
TABLE OF CONTENTS
EXECUTIVE SUMMARY .................................................................................................... ES-1
1.0

INTRODUCTION.......................................................................................................... 1-1
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8

1.9
2.0

PROPOSED ACTION AND ALTERNATIVES......................................................... 2-1
2.1
2.2

2.3
2.4
2.5
3.0

STUDY LOCATION ........................................................................................... 1-2
CBP HISTORY.................................................................................................... 1-2
CBP INTENT AND STRATEGIES .................................................................... 1-2
REGULATORY AUTHORITY .......................................................................... 1-2
PURPOSE AND NEED....................................................................................... 1-4
SCOPE OF THE ANALYSIS ............................................................................. 1-4
APPLICABLE ENVIRONMENTAL GUIDANCE, STATUTES, AND
REGULATIONS.................................................................................................. 1-4
PUBLIC INVOLVEMENT ................................................................................. 1-4
1.8.1 Cooperating Agency .............................................................................. 1-10
1.8.2 California Environmental Quality Act (CEQA) Lead Agency .............. 1-10
REPORT ORGANIZATION ............................................................................. 1-10
NO ACTION ALTERNATIVE ........................................................................... 2-1
PROPOSED ACTION ALTERNATIVE ............................................................ 2-1
2.2.1 Road Improvements ................................................................................. 2-1
2.2.2 Staging Areas ........................................................................................... 2-2
2.2.3 Water Usage ............................................................................................. 2-4
2.2.4 Construction Personnel and Equipment ................................................... 2-4
BP HILL IMPROVEMENT ALTERNATIVE ................................................... 2-4
ALTERNATIVES CONSIDERED BUT ELIMINATED................................... 2-4
SUMMARY ......................................................................................................... 2-6

AFFECTED ENVIRONMENT AND CONSEQUENCES ........................................ 3-1
3.1
3.2

3.3

3.4

PRELIMINARY IMPACT SCOPING ................................................................ 3-1
LAND USE .......................................................................................................... 3-2
3.2.1 Affected Environment .............................................................................. 3-2
3.2.2 Environmental Consequences .................................................................. 3-4
3.2.2.1 No Action Alternative .............................................................. 3-4
3.2.2.2 Proposed Action Alternative .................................................... 3-4
3.2.2.3 BP Hill Improvement Alternative ............................................ 3-4
SOILS .................................................................................................................. 3-4
3.3.1 Affected Environment .............................................................................. 3-4
3.3.2 Environmental Consequences .................................................................. 3-6
3.3.2.1 No Action Alternative .............................................................. 3-6
3.3.2.2 Proposed Action Alternative .................................................... 3-6
3.3.2.3 BP Hill Improvement Alternative ............................................ 3-6
GEOLOGY .......................................................................................................... 3-6
3.4.1 Affected Environment .............................................................................. 3-6
3.4.2 Environmental Consequences .................................................................. 3-7

West Desert Road EA

Final
February 2013

00003743
ii

3.5

3.6

3.7

3.8

3.9

3.10

3.4.2.1 No Action Alternative .............................................................. 3-7
3.4.2.2 Proposed Action Alternative .................................................... 3-7
3.4.2.3 BP Hill Improvement Alternative ............................................ 3-7
VEGETATION .................................................................................................... 3-7
3.5.1 Affected Environment .............................................................................. 3-7
3.5.2 Environmental Consequences .................................................................. 3-8
3.5.2.1 No Action Alternative .............................................................. 3-8
3.5.2.2 Proposed Action Alternative .................................................... 3-8
3.5.2.3 BP Hill Improvement Alternative ............................................ 3-9
WILDLIFE ........................................................................................................... 3-9
3.6.1 Affected Environment .............................................................................. 3-9
3.6.2 Environmental Consequences ................................................................ 3-10
3.6.2.1 No Action Alternative ............................................................ 3-10
3.6.2.2 Proposed Action Alternative .................................................. 3-10
3.6.2.3 BP Hill Improvement Alternative .......................................... 3-11
THREATENED AND ENDANGERED SPECIES........................................... 3-11
3.7.1 Affected Environment ............................................................................ 3-11
3.7.1.1 Federal .................................................................................... 3-12
3.7.1.2 Critical Habitat ....................................................................... 3-12
3.7.1.3 State ........................................................................................ 3-12
3.7.1.4 BLM Sensitive Species .......................................................... 3-13
3.7.2 Environmental Consequences ................................................................ 3-13
3.7.2.1 No Action Alternative ............................................................ 3-13
3.7.2.2 Proposed Action Alternative .................................................. 3-13
3.7.2.3 BP Hill Improvement Alternative .......................................... 3-14
WATER RESOURCES ..................................................................................... 3-14
3.8.1 Affected Environment ............................................................................ 3-14
3.8.1.1 Surface Waters ....................................................................... 3-14
3.8.1.2 Groundwater ........................................................................... 3-14
3.8.1.3 Waters of the United States and Wetlands ............................. 3-15
3.8.2 Environmental Consequences ................................................................ 3-15
3.8.2.1 No Action Alternative ............................................................ 3-15
3.8.2.2 Proposed Action Alternative .................................................. 3-15
3.8.2.3 BP Hill Improvement Alternative .......................................... 3-17
AIR QUALITY .................................................................................................. 3-17
3.9.1 Affected Environment ............................................................................ 3-17
3.9.1.1 Greenhouse Gases and Climate Change................................. 3-19
3.9.2 Environmental Consequences ................................................................ 3-20
3.9.2.1 No Action Alterative .............................................................. 3-20
3.9.2.2 Proposed Action Alternative .................................................. 3-20
3.9.2.3 BP Hill Improvement Alternative .......................................... 3-22
NOISE ................................................................................................................ 3-22
3.10.1 Affected Environment ............................................................................ 3-22
3.10.2 Environmental Consequences ................................................................ 3-23
3.10.2.1 No Action Alternative ............................................................ 3-23
3.10.2.2 Proposed Action Alternative .................................................. 3-23

West Desert Road EA

Final
February 2013

00003744
iii

3.11

3.12

3.13

3.14

3.15

3.16

3.17

3.10.2.3 BP Hill Improvement Alternative .......................................... 3-24
CULTURAL, HISTORICAL, AND ARCHAEOLOGICAL RESOURCES .... 3-24
3.11.1 Affected Environmental ......................................................................... 3-24
3.11.1.1 Current Investigations ............................................................ 3-24
3.11.1.2 Tribal Concerns ...................................................................... 3-25
3.11.2 Environmental Consequences ................................................................ 3-25
3.11.2.1 No Action Alternative ............................................................ 3-25
3.11.2.2 Proposed Action Alternative .................................................. 3-25
3.11.2.3 BP Hill Improvement Alternative .......................................... 3-25
ROADWAYS AND TRAFFIC ......................................................................... 3-26
3.12.1 Affected Environment ............................................................................ 3-26
3.12.2 Environmental Consequences ................................................................ 3-26
3.12.2.1 No Action Alternative ............................................................ 3-26
3.12.2.2 Proposed Action Alternative .................................................. 3-26
3.12.2.3 BP Hill Improvement Alternative .......................................... 3-26
AESTHETICS AND VISUAL RESOURCES .................................................. 3-26
3.13.1 Affected Environment ............................................................................ 3-26
3.13.2 Environmental Consequences ................................................................ 3-27
3.13.2.1 No Action Alternative ............................................................ 3-27
3.13.2.2 Proposed Action Alternative .................................................. 3-27
3.13.2.3 BP Hill Improvement Alternative .......................................... 3-27
HAZARDOUS MATERIALS ........................................................................... 3-27
3.14.1 Affected Environment ............................................................................ 3-27
3.14.2 Environmental Consequences ................................................................ 3-28
3.14.2.1 No Action Alternative ............................................................ 3-28
3.14.2.2 Proposed Action Alternative .................................................. 3-28
3.14.2.3 BP Hill Improvement Alternative .......................................... 3-28
SOCIOECONOMICS ........................................................................................ 3-28
3.15.1 Affected Environment ............................................................................ 3-28
3.15.1.1 Population............................................................................... 3-28
3.15.1.2 Employment, Poverty Levels, and Income ............................ 3-29
3.15.1.3 Housing .................................................................................. 3-31
3.15.2 Environmental Consequences ................................................................ 3-31
3.15.2.1 No Action Alternative ............................................................ 3-31
3.15.2.2 Proposed Action Alternative .................................................. 3-31
3.15.2.3 BP Hill Improvement Alternative .......................................... 3-32
HUMAN HEALTH AND SAFETY .................................................................. 3-32
3.16.1 Affected Environment ............................................................................ 3-32
3.16.2 Environmental Consequences ................................................................ 3-32
3.16.2.1 No Action Alternative ............................................................ 3-32
3.16.2.2 Proposed Action Alternative .................................................. 3-32
3.16.2.3 BP Hill Improvement Alternative .......................................... 3-32
SUSTAINABILITY AND GREENING............................................................ 3-32
3.17.1 Affected Environment ............................................................................ 3-32
3.17.2 Environmental Consequences ................................................................ 3-33
3.17.2.1 No Action Alternative ............................................................ 3-33

West Desert Road EA

Final
February 2013

00003745
iv

3.18

4.0

CUMULATIVE IMPACTS .......................................................................................... 4-1
4.1
4.2
4.3

5.0

3.17.2.2 Proposed Action Alternative .................................................. 3-33
3.17.2.3 BP Hill Improvement Alternative .......................................... 3-33
PALEONTOLOGICAL RESOURCES ............................................................. 3-33
3.18.1 Affected Environment ............................................................................ 3-33
3.18.2 Environmental Consequences ................................................................ 3-33
3.18.2.1 No Action Alternative .............................................................. 3-33
3.18.2.2 Proposed Action Alternative .................................................... 3-33
CBP PROJECTS .................................................................................................. 4-1
PRIVATE/OTHER AGENCY/ORGANIZATION PROJECTS ......................... 4-2
IDENTIFICATION OF CUMULATIVE EFFECTS ISSUES ............................ 4-3
4.3.1 Land Use .................................................................................................. 4-3
4.3.2 Soils.......................................................................................................... 4-3
4.3.3 Geology .................................................................................................... 4-4
4.3.4 Vegetation ................................................................................................ 4-4
4.3.5 Wildlife .................................................................................................... 4-4
4.3.6 Protected Species and Critical Habitats ................................................... 4-4
4.3.7 Water Resources ...................................................................................... 4-4
4.3.8 Air Quality ............................................................................................... 4-5
4.3.9 Noise ........................................................................................................ 4-5
4.3.10 Cultural Resources ................................................................................... 4-5
4.3.11 Aesthetics and Visual Resources ............................................................. 4-5
4.3.12 Hazardous Materials ................................................................................ 4-5
4.3.13 Socioeconomic ......................................................................................... 4-6
4.3.14 Human Health and Safety ........................................................................ 4-6

BEST MANAGEMENT PRACTICES ........................................................................ 5-1
5.1
5.2
5.3
5.4
5.5
5.6
5.7
5.8
5.9
5.10

PROJECT PLANNING/DESIGN – GENERAL CONSTRUCTION ................. 5-1
GENERAL CONSTRUCTION ACTIVITIES .................................................... 5-1
VEGETATION .................................................................................................... 5-2
WILDLIFE RESOURCES................................................................................... 5-2
PROTECTED SPECIES ...................................................................................... 5-2
WATER RESOURCES ....................................................................................... 5-5
CULTURAL RESOURCES ................................................................................ 5-5
AIR QUALITY .................................................................................................... 5-5
NOISE .................................................................................................................. 5-5
HAZARDOUS MATERIALS ............................................................................. 5-6

6.0

REFERENCES............................................................................................................... 6-1

7.0

ACRONYMS AND ABBREVIATIONS ...................................................................... 7-1

8.0

LIST OF PREPARERS ................................................................................................. 8-1

West Desert Road EA

Final
February 2013

00003746
v

LIST OF FIGURES
Figure 1-1.
Figure 2-1.
Figure 2-2.
Figure 3-1.
Figure 3-2.
Figure 5-1.

Vicinity Map ........................................................................................................ 1-3
Proposed Action Alternative Map ....................................................................... 2-3
BP Hill Improvement Alternative Map................................................................ 2-5
Land Use Map ...................................................................................................... 3-5
Waters of the U.S. within the Project Area ........................................................ 3-16
Schematic Showing Disturbed Versus Undisturbed Areas .................................. 5-4
LIST OF TABLES

Table 1-1.
Table 2-1.
Table 2-2.
Table 3-1.
Table 3-2.
Table 3-3.
Table 3-4.
Table 3-5.
Table 3-6.
Table 3-7.
Table 3-8.
Table 3-9.
Table 3-10.
Table 3-11.
Table 3-12.
Table 5-1.

Relevant Policy Documents, Invoking Actions, Regulatory Requirements, and
Status of Compliance ........................................................................................... 1-5
Alternatives Matrix .............................................................................................. 2-6
Summary of Impacts ............................................................................................ 2-7
Summary of Impacts of Project Components by Alternative .............................. 3-3
Federally Listed Species for Imperial County, California ................................. 3-12
National Ambient Air Quality Standards ........................................................... 3-18
NAAQS and CAAQS Air Quality Status in Imperial County ........................... 3-19
Total Air Emissions (tons/year) from the Proposed Action Construction versus
the de minimis Threshold Levels-Imperial County ............................................ 3-21
A-Weighted (dBA) Sound Levels of Construction Equipment and Modeled
Attenuation at Various Distances....................................................................... 3-24
Population .......................................................................................................... 3-28
Race and Ethnicity ............................................................................................. 3-29
Educational Attainment ..................................................................................... 3-29
Employment by Industry Sector (Percent of Total) ........................................... 3-30
Income and Poverty ........................................................................................... 3-30
Housing Units .................................................................................................... 3-31
Compensation for Impacts on FTHL habitat ....................................................... 5-3
LIST OF PHOTOGRAPHS

Photograph 2-1.
Photograph 2-2.
Photograph 3-1.
Photograph 3-2.

Existing border road in eastern portion of project area. ................................... 2-2
Existing border road in western portion of project area. .................................. 2-2
Vegetation in the project corridor, facing west. ............................................... 3-8
Facing west with creosote bush in foreground. ................................................ 3-8
LIST OF APPENDICES

Appendix A.
Appendix B.
Appendix C.
Appendix D.

Correspondence
Biological Survey Report
Protected Species: Federal, State, and BLM Sensitive
Air Quality Calculations

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SECTION 1.0
INTRODUCTION

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1-1

1.0

INTRODUCTION

U.S. Customs and Border Protection (CBP) has prepared this Environmental Assessment (EA) to
address the potential effects, beneficial and adverse, resulting from the proposed improvement
and construction, operation, and maintenance of approximately 1.6 miles of all-weather road
near the U.S./Mexico border within U.S. Border Patrol (USBP) El Centro Station’s Area of
Responsibility (AOR). The existing border road is impassable and creates long drive times for
agents to reach patrol areas, limiting their ability to assist with interdictions and apprehensions.
The border road improvements would occur from near Border Monument 224 (approximately N
32° 38.96544, W 115° 42.1974), to near Border Monument 225 (approximately N32° 38.89518,
W115° 43.52994). The border road would be improved to an all-weather surface road (1.4 miles
long) approximately 20 feet wide with 2-foot shoulders and include any necessary drainage
structures. A drag road would also be constructed along the north side of the all-weather surface.
Staging areas would be located approximately every 0.3 mile within the construction corridor. In
addition to the 1.4 miles of road improvement, a new access road (approximately 0.2 mile)
would be constructed leading to the BP Hill Remote Video Surveillance System (RVSS) tower
from the improved border road. This road would be a 16-foot-wide road with necessary drainage
structures and all-weather surfacing.
On April 1, 2008, the Secretary of the U.S. Department of Homeland Security (DHS), pursuant
to his authority under Section 102(c) of Illegal Immigration Reform and Immigrant
Responsibility Act (IIRIRA), exercised his authority to waive certain environmental and other
laws in order to ensure the expeditious construction of tactical infrastructure (TI) along the
U.S./Mexico border. The proposed improvement and construction, operation, and maintenance
of approximately 1.6 miles of all-weather road addressed in this EA is part of a larger TI project,
portions of which are waived from National Environmental Policy Act (NEPA) and other
Federal regulatory compliance by the Secretary of DHS. The other elements of the larger TI
project include the improvement, operation, and maintenance of two staging areas, two access
roads, and border road to the east and west of the proposed project area. As part of the Secretary
of the DHS’s commitment to environmental stewardship under the waiver, CBP published the
May 2008 Environmental Stewardship Plan (ESP) for the Construction, Operation, and
Maintenance of Tactical Infrastructure, U.S. Border Patrol, El Centro Sector, California, which
describes the proposed TI and any potential environmental impacts.
USBP El Centro Station is one of four stations composing the El Centro Sector, along with the
Calexico, Indio, and Riverside stations in California. USBP El Centro Station’s AOR includes
37.1 linear miles of the U.S./Mexico border. The remoteness of, and travel time to, the west
desert area of USBP El Centro Station’s AOR limits the capability of law enforcement agents to
rapidly respond to illegal activity. By providing an all-weather road near the border, agent
response time to illegal cross-border activities would be greatly enhanced, and agents could be
more efficiently and safely deployed to patrol the more remote sections of USBP El Centro
Station’s AOR.

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1.1

STUDY LOCATION

The proposed all-weather roads are located west of the All-American Canal adjacent to and
within U.S. Bureau of Land Management (BLM) lands, near the U.S./Mexico border within
USBP El Centro Station’s AOR. Specifically, the project is located adjacent to and within the
BLM’s Yuha Desert Area of Critical Environmental Concern (ACEC). The City of Calexico,
California, is located approximately 10 miles east of the project area, while the City of El Centro,
California, is located approximately 11.5 miles northeast of the project area (Figure 1-1). Access
to the project area is limited to primitive roads with ingress and egress locations along State
Route (SR) 98.
1.2

CBP HISTORY

In 1924, Congress created the USBP to serve as the law enforcement entity of the Immigration
and Naturalization Service (INS), and it did so until November 25, 2002, when Congress
transferred all INS responsibilities to the newly created DHS with the passage of the Homeland
Security Act of 2002 (Public Law [PL] 107-296). USBP was officially transferred to DHS/CBP
on March 1, 2003.
1.3

CBP INTENT AND STRATEGIES

In the aftermath of the September 11, 2001 terrorist attacks on the United States and the
subsequent formation of DHS, CBP was created by unifying all frontline personnel and functions
with law enforcement responsibilities at our Nation’s borders. The mission of CBP is to secure
the borders of the United States and to prevent terrorists and terrorist weapons from entering the
United States (CBP 2012). As an important component of CBP, USBP’s mission is to detect and
prevent terrorists and terrorist weapons from entering the country between official Ports of Entry
(POE). USBP will continue to advance its mission to detect, interdict, and apprehend those who
attempt to illegally enter or smuggle any person or contraband across the sovereign borders of
the United States. While previous years’ strategies have applied an appropriate mix of
infrastructure, technology, and personnel to effectively manage land borders in a resource-based
approach to border security, the new USBP National Strategy (2012-2016) extends a risk-based
approach to countering the threat environment through information, integration, and rapid
response. Assets are used to execute the mission functions of predicting illicit activity, detecting
and tracking border crossings, identifying and classifying the detections, and responding to and
resolving suspect border crossings as threats are identified through intelligence efforts and
prioritized for response and targeted enforcement.
1.4

REGULATORY AUTHORITY

The primary sources of authority granted to USBP agents are the Immigration and Nationality
Act (INA) of 1952 (PL 82-414) contained in Title 8 of the United States Code (USC) “Aliens
and Nationality” and other statutes relating to the immigration and naturalization of aliens. The
secondary sources of authority are administrative regulations implementing those statutes,
judicial decisions, and administrative decisions of the Board of Immigration Appeals. In
addition, the IIRIRA of 1996 (PL 104-208) and, subsequently, the Homeland Security Act
West Desert Road EA

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California
Imperial County

Figure 1-1: Vicinity Map

·

0

0.5

1

1.5

May 2012

2
Miles

Project Location

Waived Areas

1-3
00003752

00003753
1-4

mandate that DHS acquire and improve equipment and technology along the border, hire and
train new agents for the border region, and develop effective border enforcement strategies.
1.5

PURPOSE AND NEED

The purpose of the Proposed Action is to increase border security within the USBP El Centro
Sector with an ultimate objective of reducing illegal cross-border activity by providing safer and
more efficient access for USBP agents along the U.S./Mexico border in the west desert area of
the USBP El Centro Station’s AOR and to BP Hill. The primary need for the Proposed Action is
because of the remoteness of the west desert area and the impassability of the existing road,
which creates long drive times for agents to reach patrol areas and limits their ability to assist
with interdictions and apprehensions. An additional need for the Proposed Action is to provide
agents with the infrastructure necessary to carry out USBP’s mission.
1.6

SCOPE OF THE ANALYSIS

The EA will include the analysis of effects resulting from the improvement, operation, and
maintenance of an all-weather road and construction, operation, and maintenance of a new
access road to BP Hill. The proposed road improvements and construction would include
development of lands within El Centro Station’s AOR in the Yuha Desert ACEC/Yuha Desert
flat-tailed horned lizard (FTHL) Management Area, both of which are managed by the BLM.
The potentially affected biological and human environment would include resources associated
with the undeveloped land located in south-central Imperial County; however, most potential
effects would be limited to the construction site and immediately adjacent resources.
1.7

APPLICABLE ENVIRONMENTAL GUIDANCE, STATUTES, AND
REGULATIONS

The EA will be prepared by CBP in accordance with the National Environmental Policy Act
(NEPA) of 1969 (42 USC 4321-4347) and the Council on Environmental Quality (CEQ)
regulations for implementing NEPA (40 Code of Federal Regulations [CFR] 1500-1508), BLM
planning guide (BLM NEPA Handbook H-1790-1), as well as the DHS “Environmental
Planning Directive” (Directive 023-01). Other pertinent environmental statutes, regulations, and
compliance requirements that will guide the preparation of the EA are summarized in Table 1-1.
This list, however, is not intended to be an all-inclusive list of applicable Federal laws and
regulations.
1.8

PUBLIC INVOLVEMENT

Consultation and coordination with Federal and state agencies would occur during preparation of
the document. The list below includes contacts that were made during the development of the
action alternatives and writing of the EA. Copies of correspondence are provided in Appendix
A. Formal and informal coordination will be conducted with the following agencies:
U.S. Fish and Wildlife Service (USFWS)
U.S. Army Corps of Engineers, Los Angeles District (USACE)
U.S. Section, International Boundary and Water Commission (USIBWC)
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West Desert Road EA

7 USC § 9601 et seq.

Farmland Protection Policy
Act of 1981

16 USC § 1531 et seq.

Endangered Species Act
(ESA) of 1973

42 USC § 9601 et seq.

Comprehensive
Environmental Response,
Compensation and
Liability Act of 1980

16 USC § 470 et seq.

Clean Air Act of 1963

59 AIM 3

Bureau of Indian Affairs
(BIA) Policy,
Requirements, and
Responsibilities for NEPA
Compliance

16 United States Code
(USC) § 470 et seq.

Archaeological Resources
Protection Act of 1979

Policy Document

Natural Resources
Conservation
Service

U.S. Fish and
Wildlife Service
(USFWS)

USEPA

Environmental
Protection Agency
(USEPA)

BIA

Department of
Interior

Administrative
Authority
Requirements for Compliance

7 CFR 658

Any Federal action

50 CFR 402.03

All actions in which there is discretionary
Federal involvement or control and
potential to affect protected species.

40 CFR 302

Release or threatened release of a
hazardous substance

40 CFR 51

Any Federal action where the total of
direct and indirect emissions in a nonattainment area would equal or exceed the
provided rates

40 CFR Parts 1500-1508

Any undertaking by Federal agencies on
lands administered by a sovereign Native
American tribe

Identify and take into account the
adverse effects on the protection of
farmland

Determination of no jeopardy to listed
species and no destruction or adverse
modification of critical habitat through
consultation with the USFWS

Development of emergency response
plans, notification, and cleanup

Project emission levels were
determined to be less than de minimis
thresholds; therefore, a determination
of conformity with applicable
implementation plan is not required

Adherence to guidelines set forth by the
Council on Environmental Quality
(CEQ) for implementing NEPA (40
Code of Federal Regulations [CFR]
1500-1508) on lands administered by a
sovereign Native American on tribal
property

Excavation, removal, damage, or other
alteration or defacing; or attempt to
excavate, remove, damage, or otherwise
alter or deface any archaeological resource
located on public lands
43 Code Federal Regulations (CFR) 7.4

Because activities are exclusively for
purposes other than the excavation
and/or removal of archaeological
resources, even though those activities
might incidentally result in the
disturbance of archaeological
resources, no permit shall be required

Invoking Action

No prime
farmland soils
would be
impacted

No effect on any
Federally
protected species

To be completed
by U.S. Customs
and Border
Protection (CBP)
during design
and operation

Only minor
emissions would
occur during
construction

Project is not
located on tribal
lands

Section 106
consultation is
ongoing

No adverse
impact on
historic
properties.

Status of
Compliance

Table 1-1. Relevant Policy Documents, Invoking Actions, Regulatory Requirements, and Status of Compliance*

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February 2013

West Desert Road EA

16 USC § 470 et seq.

36 CFR 800.3

Any undertaking by Federal

Advisory Council
on Historic
Preservation

National Historic
Preservation Act of 1966

25 CFR Part 169
Any Federal action resulting in the
potential take of any migratory bird, or the
parts, nests, or eggs of such bird

Any Federal action resulting in a trust land
use agreement for use of tribal property
between a Federal agency and a sovereign
Native American tribe

40 CFR 122

Discharge of pollutants

40 CFR 112

Storage, use, or consumption of oil and oil
products, which could discharge oil in
quantities that could affect water quality
standards, into or upon the navigable
Waters of the U.S.

Invoking Action

50 CFR 21.11

USFWS

BIA

USEPA

Administrative
Authority

16 USC § 703

Migratory Bird Treaty Act
of 1918

25 CFR Part 162

IIM Land Use Agreement
Direct Payment
Arrangement

CWA

33 USC § 1251 et seq.

Federal Water Pollution
Control Act of 1977 (also
known as Clean Water Act
or CWA)

Policy Document

Table 1-1, continued

Assessment of effects through
consultation with the Advisory Council
on Historic Preservation

Avoidance of take or application for
permit

Agreement between CBP and the
respective Native American tribe for
payment of trust land use

Obtain a general National Pollutant
Discharge Elimination System Permit

Preparation of a Spill Prevention,
Control, and Countermeasures Plan

Requirements for Compliance

Section 106
consultation is
ongoing

Proposed
surveys prior to
any construction
beginning during
nesting season
No adverse
impact on
historic
properties

Project is not
located on tribal
lands

To be completed
by CBP or
contractor.
Minor impacts
on Waters of the
United States, a
USACE
Nationwide
Permit 14 would
be used

To be completed
by CBP or
contractor

Status of
Compliance

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West Desert Road EA

42 FR 26,691 (May 24,
1977)

EO 11990: Protection of
Wetlands

42 Federal Register (FR)
26,951 (May 24, 1997)

Executive Order (EO)
11988: Floodplain
Management

42 USC § 6901 et seq.

Resource Conservation and
Recovery Act (RCRA) of
1976

29 USC § 651 et seq.

Occupational Health and
Safety Act of 1970

Policy Document

Table 1-1, continued

U.S. Army Corps
of Engineers,
USEPA

Water Resources
Council, Federal
Emergency
Management
Agency, Council
on Environmental
Quality (CEQ)

USEPA

Occupational
Safety and Health
Administration,
Department of
Labor

Administrative
Authority
To be completed
by CBP during
design and
operation

Status of
Compliance

To be completed
by CBP during
design and
operation

Procure designated items composed of
the highest percentage of recovered
materials practicable

To be completed
by CBP during
design and
operation

Take action to minimize the
destruction, loss, or degradation of
wetlands, and to preserve and enhance
the natural and beneficial values of
wetlands

Federally undertaken, financed, or assisted
construction, and improvements;
conducting Federal activities affecting land
use, including but not limited to water and
related land resources planning, regulation,
and licensing activities

No impacts on
wetlands

No floodplains
would be
impacted by the
Proposed Action

Determination of hazardous or nonhazardous nature of solid waste, obtain
an EPA identification number if
necessary, properly accumulate
hazardous waste, and maintain a record
Determine whether the proposed action
would occur in a floodplain, then
evaluate potential effects of any action
in a floodplain

To be completed
by CBP during
design and
operation

Recovery of high-grade paper,
residential materials, and corrugated
containers

To be completed
by CBP during
design and
operation

Adherence to guidelines for waste
storage and safety and collection
equipment, frequency, and
management

Adherence to occupational health and
safety standards

Requirements for Compliance

Acquisition and management of Federal
lands; Federally undertaken, financed, or
assisted construction; conducting Federal
activities affecting land use within a
floodplain

40 CFR 262.10(c)

Treatment, storage, or disposal of
hazardous waste on-site

40 CFR 246

40 CFR 247
Recovery of resources from solid waste
through source separation

40 CFR 243
Procurement of more than $10,000
annually of products containing recovered
materials

Collection of residential, commercial, and
institutional solid wastes and street wastes

29 CFR 1910.5(a)

Employees performing in a workplace

Invoking Action

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West Desert Road EA
Operation and maintenance of a Federal
facility

CEQ

USEPA,
Department of
Energy (DOE)

64 FR 30851 (June 3,
1999)

72 FR No. 17,3919
(January 24, 2007)
EO 13123: Greening the
Government Through
Efficient Energy
Management

Reduction of energy, waste production,
and water consumption, and improved
efficiency of transportation within Federal
agencies

No effects on
minority
communities or
low-income
communities.
Item eliminated
from EA

No effects on
minority
communities or
low-income
communities.
Item eliminated
from EA

Status of
Compliance

To be completed
by CBP during
design and
operation as
appropriate

To be completed
by CBP during
design and
operation as
appropriate

Incorporate waste prevention, energy
efficiency, and recycling in the
agency’s daily operations

Any Federal action that has the potential to
place children at higher health and safety
risks

62 FR 19883 (April 23,
1997)
EO 13423: Strengthening
Federal Environmental,
Energy, and Transportation
Management

Identify and assess environmental
health risks and safety risks that may
disproportionately affect children

All programs or activities receiving
Federal financial assistance that affect
human health or the environment

Requirements for Compliance

Analyze the environmental effects,
including human health, economic, and
social effects of CBP actions, including
effects on minority communities and
low-income communities

Invoking Action

USEPA

USEPA

Administrative
Authority

59 FR 7629 (February 11,
1994)
EO 13045: Protection of
Children from
Environmental Health
Risks and Safety Risks

EO 12898: Federal Actions
to Address Environmental
Justice in Minority
Populations and LowIncome Populations

Policy Document

Table 1-1, continued

Reduce emissions of greenhouse gases,
reduce energy consumption, strive to
expand use of renewable energy,
reduce use of petroleum, and reduce
water consumption

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1-8

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February 2013

West Desert Road EA

*Not All-Inclusive

74 FR 52117 (October 8,
2009)

EO 13514: Federal
Leadership in
Environmental, Energy,
and Economic Performance

Policy Document

Table 1-1, continued

CEQ

Administrative
Authority

Construction, operation, and maintenance
of a Federal facility; aircraft operations
and worker commutes

Invoking Action

Status of
Compliance

To be completed
by CBP during
design and
operation as
appropriate

Requirements for Compliance
Increase energy efficiency; measure,
report, and reduce greenhouse gas
emissions from direct and indirect
activities; conserve and protect water
resources through efficiency, reuse, and
stormwater management; eliminate
waste, recycle, and prevent pollution;
design, construct, maintain, and operate
high-performance sustainable buildings
in sustainable locations

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00003759
1-10

California Department of Fish and Game (CDFG)
California Environmental Protection Agency (CalEPA)
California Regional Water Quality Control Board (RWQCB)
California State Historical Preservation Officer (SHPO)
BLM
Imperial Irrigation District (IID)
Native American Tribes
This draft EA was made available for public review for 30 days, and the Notice of Availability
(NOA) was published in the Imperial Valley Press on November 15, 2012. The draft EA was
also available electronically at http://ecso.swf.usace.army.mil/Pages/Publicreview.cfm. In
addition, the draft EA was available for review at El Centro Public Library, 539 West State
Street, El Centro, California 92243 and the Calexico City Library, 850 Encinas Avenue,
Calexico, California 92231, from November 15, 2012 to December 15, 2012. During this review
period, only five comment letters were received. These letters and the responses to the
comments are included in Appendix A, along with other correspondence sent or received during
the preparation of the EA.
1.8.1 Cooperating Agency
A request to be a cooperating agency was submitted to and accepted by BLM, since all of the
proposed project would be located within lands managed by BLM. A copy of the cooperation
letter is in Appendix A. BLM is required to manage the natural resources on their lands to
ensure sustainability of grazing leases, recreational opportunities, cultural resources, and natural
resources.
1.8.2 California Environmental Quality Act (CEQA) Lead Agency
Identification of the appropriate CEQA lead agency is the necessary first step toward compliance
with CEQA. Because the RWQCB is the only state agency with permitting authority over the
proposed project, it is the appropriate lead agency. It is assumed that the RWQCB will
determine that a Mitigated Negative Declaration would be the appropriate CEQA document and
that this EA can be used in lieu of it.
1.9

REPORT ORGANIZATION

The EA is organized into eight major sections. Section 1.0 is the introduction, and Section 2.0
describes all alternatives considered for the project. Section 3.0 discusses the environmental
resources potentially affected by the project and the environmental consequences for each of the
viable alternatives. Section 4.0 discusses cumulative impacts, and environmental design
measures are discussed in Section 5.0. Sections 6.0, 7.0, and 8.0 present a list of the references
cited in the document, a list of acronyms and abbreviations used in the document, and a list of
the persons involved in the preparation of the document, respectively. Correspondence
generated during the preparation of the EA is presented in Appendix A. Appendix B is the
Biological Survey Report, Appendix C is the BLM and California list of protected species, and
Appendix D is the Air Quality Calculations completed for this project.

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00003760

SECTION 2.0
PROPOSED ACTION AND ALTERNATIVES

00003761

00003762
2-1

2.0

PROPOSED ACTION AND ALTERNATIVES

There are three alternatives carried forward for evaluation in the EA: 1) the No Action
Alternative, 2) the Proposed Action Alternative (Preferred Alternative), 3) and the BP Hill
Improvement Alternative. The following sections discuss the components necessary for the
proposed road improvements and the proposed alternatives for this project.
On April 1, 2008, the Secretary of DHS, pursuant to his authority under Section 102(c) of
IIRIRA, exercised his authority to waive certain environmental and other laws in order to ensure
the expeditious construction of TI along the U.S./Mexico border. The proposed improvement
and construction, operation, and maintenance of approximately 1.6 miles of all-weather road
addressed in this EA is part of a larger TI project, portions of which are waived from NEPA and
other Federal regulatory compliance by the Secretary of DHS. The other elements of the larger
TI project include the improvement, operation, and maintenance of two staging areas, two access
roads, and border road to the east and west of the proposed project area. As part of the Secretary
of the DHS’s commitment to environmental stewardship under the waiver, CBP published the
May 2008 ESP for the Construction, Operation, and Maintenance of Tactical Infrastructure, U.S.
Border Patrol, El Centro Sector, California, which describes the proposed TI and any potential
environmental impacts.
2.1

NO ACTION ALTERNATIVE

The No Action Alternative would preclude the improvement and construction, operation, and
maintenance of approximately 1.6 miles of road as described in the Proposed Action. USBP
agents would continue to face safety related issues while trying to maintain and access the BP
Hill RVSS tower, would have long drive times to reach patrol areas, and would be restricted in
their abilities to assist with interdictions and apprehensions. The No Action Alternative does not
meet the purpose and need for the proposed project but will be carried forward for analysis, as
required by the CEQ regulations, and will serve as the baseline for comparison to other action
alternatives.
2.2

PROPOSED ACTION ALTERNATIVE

CBP proposes to improve and construct, operate, and maintain approximately 1.6 miles of road
near the U.S./Mexico border (see Figure 1-1). The Proposed Action comprises improvement of
an existing border road and construction of a new access road to the top of BP Hill. The
Proposed Action Alternative is CBP's Preferred Alternative.
2.2.1 Road Improvements
Improvements would include widening the existing border road (Photographs 2-1 and 2-2) for
1.4 miles from a width of 15 feet to a width of 20 feet with 2-foot shoulders, installing drainage
ditches, rip-rap lining at inlet and outlet structures, and other ancillary structures (e.g., low-water
crossings and culverts), and applying an all-weather surface. There is a possibility that bridges
would be used in lieu of low-water crossings or culverts. These bridges would be one-piece,
prefabricated, delivered onsite, and installed within the road footprint. A drag road
approximately 10 feet wide would also be constructed along the northern boundary of the
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00003763
2-2

improved border road. The combined temporary and permanent footprint of the road
improvements would be approximately 120 feet wide by 1.4 miles long. Within this footprint,
approximately 80 feet would be temporary and 40 feet would be permanent.

Photograph 2-1. Existing border road in eastern portion of
project area.

Photograph 2-2. Existing border road in western portion
of project area.

The new access road to BP Hill (0.2 mile in length) would be constructed to 16 feet wide and
designed to not exceed a 12 percent slope. Construction would include the installation of
drainage ditches and other ancillary structures, as well as the application of all-weather
surfacing. The total permanent footprint for the new access road to BP Hill could be 30 feet
wide by 0.2 mile long. The temporary footprint could be 90 feet wide by 0.2 mile long. Upon
completion of the improvements and construction activities, all temporarily disturbed areas
would be rehabilitated per BLM guidelines.
All-weather surfacing consists of adding aggregate and a soil-stabilizing or binding agent (e.g.,
PennzSuppress®) to the surface of the road. This would be done once the construction is
completed to reduce erosion and maintenance activities. Maintenance of this road would include
filling holes with aggregate, smoothing the road, and applying a top shot of the soil-stabilizing
agent to the surface on at least an annual basis to ensure road surface longevity. Water bars or
other water conveyance techniques would be installed at various locations along the road to
direct stormwater into parallel ditches or downslope to reduce erosion of the road surface.
2.2.2 Staging Areas
Five staging areas (50 feet by 50 feet) would be constructed along the proposed all-weather road
(Figure 2-1). The total footprint of the staging areas would not exceed 0.3 acres. Upon
completion of the improvement activities, all temporarily impacted areas, such as the staging
areas, would be rehabilitated.

West Desert Road EA

Final
February 2013

Project Location

Figure 2-1: Proposed Action Alternative Map

·

0

1,000

2,000

3,000
Feet

Staging Area (50 ft x 50 ft)

"
)

Waived Areas

Road Improvements

October 2012

BP Hill Proposed Road Construction

Waived Staging Area

)
"

2-3
00003764

00003765
2-4

2.2.3 Water Usage
In order to accomplish the road improvements and construction efforts, CBP would use a
commercial vendor or obtain water from the All-American Canal, if possible. Water would be
trucked into the site via a water truck or portable water tank and delivered to the project area in
order to provide the correct moisture content for the soil during improvement and construction
activities. Water would also be used to control fugitive dust emissions during those activities. It
is estimated that approximately 4.9 acre-feet per mile of roadway would be needed for
construction purposes (Fitts 2012).
2.2.4 Construction Personnel and Equipment
CBP maintenance staff, Joint Task Force North units, National Guard units, or private
contractors would complete the proposed construction and improvements of the roadways.
Equipment staging would occur at the staging areas discussed above. The equipment anticipated
to be used during the construction includes a backhoe, trencher, bulldozer, grader, dump truck,
front-end loader, flatbed truck, water truck, and roller/compactor.
2.3

BP HILL IMPROVEMENT ALTERNATIVE

The third alternative carried forward for analysis includes the improvement, operation, and
maintenance of the existing border road and construction and use of the five new staging areas as
presented in the Proposed Action Alternative. However, rather than construct a new access road
to the BP Hill RVSS tower site, CBP would improve the existing access road, which is
approximately 0.3 mile long, by widening it to 16 feet, installing ancillary structures, all-weather
surfacing, and reducing the grade through cut and fill activities (Figure 2-2). The total footprint
for the improvement of the existing BP Hill access road would be 30 feet wide by 0.3 mile long.
Only an area 16 feet wide would be permanently disturbed. The remaining 14 feet of footprint
would be disturbed temporarily during improvement efforts. Additionally, all temporarily
impacted areas would be rehabilitated upon completion of the construction and improvement
activities.
2.4

ALTERNATIVES CONSIDERED BUT ELIMINATED

Two alternatives were considered but eliminated from further consideration. The first alternative
was to construct a new road parallel to the U.S./Mexico border within the 60-foot Roosevelt
Reservation. However, the local topography includes towering hills and deep ravines that would
require extensive earth moving and engineering. Therefore, this alternative was eliminated from
further consideration.
The other alternative considered but eliminated was to only improve limited areas within the
existing border road and BP Hill. Due to the impassability of the entire road, only improving
limited areas would still leave a vulnerable gap in the border road and would not meet the
purpose and need of the proposed project. Therefore, this alternative was eliminated from
further consideration.

West Desert Road EA

Final
February 2013

Project Location

0

Figure 2-2: BP Hill Improvement Alternative Map

·

1,000

2,000

3,000
Feet

Staging Area (50ft x 50ft)

"
)

Waived Areas

October 2012

BP Hill Existing Road
Road Improvements

Waived Staging Area

)
"

2-5
00003766

00003767
2-6

2.5

SUMMARY

The No Action Alternative, Proposed Action Alternative, and BP Hill Improvement Alternative
have been carried forward for analysis. As shown in Table 2-1, only the Proposed Action and
BP Hill Improvement Alternative fully support the purpose and need as described in Section 1.3.
Table 2-2 summarizes the impacts of the Proposed Action Alternative, No Action Alternative,
and the BP Hill Improvement Alternative on the resources evaluated in the EA.
Table 2-1. Alternatives Matrix
No Action
Alternative

Proposed
Action
Alternative

BP Hill
Improvement
Alternative

Will the alternative provide increased effectiveness for
USBP agents in the performance of their duties?

No

Yes

Yes

Will the alternative provide safe access to the west desert
area within the El Centro Station’s AOR?

No

Yes

Yes

Will the alternative provide a more safe, effective, and
efficient working environment for USBP agents?

No

Yes

Yes

Purpose and Need

West Desert Road EA

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February 2013

BP Hill Improvement
Alternative

West Desert Road EA

Geology

Wildlife

Vegetation

Negligible impacts on geologic resources would
occur as a result of this alternative.

No direct impacts on geologic
resources would occur.

Soils

This alternative would have
impacts similar to those
described for the Proposed
Action Alternative. However,
up to 0.2 acre less would be
developed under this alternative.

Up to 7.5 acres of soils would be lost as a result of
the Proposed Action Alternative. Temporary impacts
on up to 23.5 acres would occur; however, this area
would be rehabilitated upon completion of the
construction activities. Negligible impacts on soils
would occur as a result of the Proposed Action.

No direct impacts on soils would
occur. However, long-term indirect
impacts on soils would continue as a
result of CBV activities.

Land Use

This alternative would have
impacts similar to those
described for the Proposed
Action Alternative. However,
up to 0.2 acre less would be
developed under this alternative.

Up to 7.5 acres of vegetation would be lost as a result
of the Proposed Action Alternative. Temporary
impacts on up to 23.5 acres would occur; however,
this area would be rehabilitated upon completion of
the construction activities. Negligible impacts on
vegetation would occur as a result of the Proposed
Action Alternative.

This alternative would have
impacts similar to those
described for the Proposed
Action Alternative. However,
up to 0.2 acre less would be
developed under this alternative.
The same impacts would occur
as described in the Proposed
Action Alternative.

The Proposed Action would change the land use of
up to 7.5 acres from undeveloped to CBP
infrastructure, which is considered a moderate impact
on land use. This land use would be in compliance
with BLM guidance and policy for the proposed
project.

No improvements or construction
would occur within the project area.
Therefore, there would be no direct
impacts. However, long-term
indirect impacts on land use would
continue as a result of illegal crossborder violator (CBV) activities.

No direct impacts would occur.
However, long-term indirect impacts
on vegetation communities would
continue as a result of illegal CBV
activities that create trails, damage
vegetation, and promote the dispersal
and establishment of invasive
species.
Under the No Action Alternative, no
direct impacts on wildlife habitats
would occur. However, illegal crossborder activity would continue to
disturb wildlife and degrade wildlife
habitat.

This alternative would have
impacts similar to those
described for the Proposed
Action Alternative. However,
up to 0.2 acre less would be
developed under this alternative.

Proposed Action Alternative

No Action Alternative

Affected
Environment

Table 2-2. Summary of Impacts

Wildlife habitat would be permanently and
temporally impacted. However, due to the habitat
being locally and regionally common any impacts are
considered negligible.

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2-7

Final
February 2013

Proposed Action Alternative

West Desert Road EA

Under the No Action Alternative,
there would be no direct impacts on
threatened or endangered species or
their habitats. However, the indirect
and long-term impacts of CBV
activity on habitats throughout the
project region and surrounding areas
would continue to disturb threatened
or endangered species and their
habitats.

Under the No Action Alternative, no
direct impacts on cultural resources
would occur. However, cultural
resources sites would continue to be
impacted by illegal CBV activities.

No equipment would be installed, so
no direct impacts on air quality from
construction would occur.

Under the No Action Alternative, no
direct impacts on noise would occur.

No impacts on aesthetic or visual
resources would occur because no
construction activities would take
place. However, a reduction of
aesthetic and visual resources created
by CBV activities and resulting law
enforcement actions would continue
and likely increase.

Protected
Species

Cultural
Resources

Air Quality

Noise

Aesthetics and
Visual
Resources

The Proposed Action Alternative would have a longterm, minor adverse effect on the viewshed and
aesthetic qualities of the project area.

No adverse effects on architectural or aboveground
resources that are eligible for the National Register of
Historic Places (NRHP) are anticipated, and no
adverse effects on cultural resources are anticipated
from the implementation of the Proposed Action
Alternative.
Temporary and minor increases in air emissions
would occur from the use of heavy equipment during
improvement or construction of the roads. Minor,
long-term beneficial impacts would occur do the use
of the all-weather surface. There would be no
violations of air quality standards and no conflicts
with the state implementation plans (SIP); therefore,
impacts on air quality from the implementation of the
Proposed Action Alternative would be minor.
The noise impacts from construction and
maintenance activities would be short-term and
minor.

The Proposed Action Alternative would have no
effects on Federally listed or state-listed species.
However, the FTHL (Phrynosoma mcallii), which is
a conservation species was observed within the
project area. CBP would mitigate impacts per the
Flat-Tailed Horned Lizard Rangewide Management
Strategy to a negligible level. No major impacts
would occur on the FTHL.

No Action Alternative

Affected
Environment

Table 2-2, continued

The same impacts would occur
as described in the Proposed
Action Alternative.

The same impacts would occur
as described in the Proposed
Action Alternative.

The same impacts would occur
as described in the Proposed
Action Alternative.

The same impacts would occur
as described in the Proposed
Action Alternative.

The same impacts would occur
as described in the Proposed
Action Alternative.

BP Hill Improvement
Alternative

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2-8

Final
February 2013

West Desert Road EA

Sustainability
and Greening

Human Health
and Safety

Socioeconomics

Hazardous
Materials

Affected
Environment

Table 2-2, continued

BP Hill Improvement
Alternative

No major adverse impacts would occur as a result of
the Proposed Action Alternative.

No major adverse impacts would occur as a result of
the Proposed Action Alternative.

The same impacts would occur
as described in the Proposed
Action Alternative.

The same impacts would occur
as described in the Proposed
Action Alternative.

The same impacts would occur
as described in the Proposed
Action Alternative.

The No Action Alternative would not
contribute any hazardous waste or
materials to the project area, as no
construction would take place.

No major adverse impacts would occur as a result of
the Proposed Action Alternative.

The Proposed Action Alternative would not result in
the exposure of the environment or the public to any
hazardous materials. The potential exists for minor
releases of petroleum, oil, and lubricants (POL)
during construction or operational activities. Best
management practices (BMP) would be put in place
to minimize any potential contamination at the
proposed site during construction activities and
operation.

The No Action Alternative would
result in no new impacts on
socioeconomics within the region, as
no road construction and
improvements would occur.
No construction or improvements
would occur, so no direct impacts
would occur. However, USBP
agents would continue to face safety
related issues while trying to
maintain and access the BP Hill
RVSS tower, as well as patrol the
existing border road.
No construction or improvements
would occur, so no direct impacts
would occur.

The same impacts would occur
as described in the Proposed
Action Alternative.

Proposed Action Alternative

No Action Alternative

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February 2013

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2-10

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00003772

SECTION 3.0
AFFECTED ENVIRONMENT AND CONSEQUENCES

00003773

00003774
3-1

3.0

AFFECTED ENVIRONMENT AND CONSEQUENCES

3.1

PRELIMINARY IMPACT SCOPING

This section of the EA describes the natural and human environment that exists within the
project site and region of influence (ROI), and the potential impacts of the Proposed Action
Alternative, BP Hill Improvement Alternative, and No Action Alternative outlined in Section 2.0
of this document. The ROI for this project is Imperial County. Only those resources with the
potential to be affected by the Proposed Action are described, per CEQ regulation (40 CFR
1501.7 [3]). The impact analysis presented in this EA is based upon existing regulatory
standards, scientific and environmental knowledge, and best professional opinions.
Impacts (consequence or effect) can be either beneficial or adverse, and can be either directly
related to the action or indirectly caused by the action. Direct impacts are those effects that are
caused by the action and occur at the same time and place (40 CFR 1508.8[a]). Indirect impacts
are those effects that are caused by the action and are later in time or further removed in distance,
but are still reasonably foreseeable (40 CFR 1508.8[b]). As discussed in this section, the
alternatives evaluated may create temporary (lasting the duration of construction), short-term (up
to 3 years), long-term (greater than 3 years), or permanent impacts or effects.
Impacts on each resource can vary in degree or magnitude from a slightly noticeable change to a
total change in the environment. For the purpose of this analysis, the intensity of impacts will be
classified as negligible, minor, moderate, or major. The intensity thresholds are defined as
follows:
Negligible: A resource would not be affected or the effects would be at or below the level
of detection, and changes would not result in any measurable or perceptible
consequences.
Minor: Effects on a resource would be detectable, although the effects would be
localized, small, and of little consequence to the sustainability of the resource. Mitigation
measures, if needed to offset adverse effects, would be simple and achievable.
Moderate: Effects on a resource would be readily detectable, long-term, localized, and
measurable. Mitigation measures, if needed to offset adverse effects, would be extensive
and likely achievable.
Major: Effects on a resource would be obvious, long-term, and would have substantial
consequences on a regional scale. Extensive mitigation measures to offset the adverse
effects would be required, and success of the mitigation measures would not be
guaranteed.
Some resource discussions are limited in scope due to the lack of direct effect from the proposed
project on the resource, or because that particular resource is not located within the project area.
Resources dismissed from further discussion are:

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00003775
3-2

Wild and Scenic Rivers
The proposed road improvements and construction would not affect any reach of river
designated as Wild and Scenic, as none are located in the vicinity of the proposed corridor.
Utilities and Infrastructure
The road improvements would not require an increase in electrical demand, and no increase on
other infrastructure is anticipated.
Aquatic Resources
There are no perennial waterbodies near the project area. Only intermittent waterbodies, which
are predominantly dry most of the year and have no flowing water except directly after a rainfall
event, are found in the project area. Therefore, no impacts on aquatic environments or species
would be anticipated.
Floodplains
The Federal Emergency Management Agency (FEMA) indicates that the project corridor area is
located within a 500-year floodplain (FEMA 2008). This area has a 0.002 percent annual chance
to flood; therefore, the risk of flooding is very low. The proposed road construction and
improvements would not result in an increase of flood risk, duration, elevation, or patterns.
Environmental Justice
EO 12898 Federal Actions to Address Environmental Justice in Minority Populations and LowIncome Populations requires the consideration of impacts and adverse effects on minority
populations and low-income populations. The project corridor is located along an existing
highway in rural areas with no surrounding community nearby. Adverse impacts on minority
and low-income populations would not occur.
Protection of Children
EO 13045, Protection of Children from Environmental Health Risks and Safety Risks, requires
each Federal agency to identify and assess environmental health risks and safety risks that may
disproportionately affect children and ensure that its policies, programs, activities, and standards
address disproportionate risks to children that result from environmental health risks or safety
risks. No children live in proximity to the project corridor; therefore, the road improvements and
construction would not adversely affect any children.
The anticipated permanent and temporary impacts resulting from the proposed infrastructure in
the project corridor are summarized in Table 3-1. These impacts are considered worst case
scenario and represent the maximum acreage anticipated as a result of improvement and
construction activities.
3.2

LAND USE

3.2.1 Affected Environment
The project corridor is located within the Yuha Basin ACEC on lands managed by BLM. The
Yuha Basin ACEC was designated by the BLM for the purpose of protecting sensitive natural
and cultural resources as part of the BLM California Desert District multiple use plan (BLM
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February 2013

1.4

Miles

West Desert Road EA
1.4

BP Hill Roadway Construction (90-foot ROW)

*Acreages and widths of road improvements or construction are considered maximum anticipated.

TOTAL ACRES IMPACTED IN PROJECT FOOTPRINT

Total Temporary Impacts

Staging Area (50 feet by 50 feet)

BP Hill Roadway Improvement (24-foot ROW)

0.2

Roadway Improvements (80-foot ROW)

TEMPORARY IMPACTS

Total Permanent Impacts

BP Hill Roadway Improvement (All-Weather Road, up to 16-foot ROW)

0.2

BP Hill Roadway Construction All-Weather Road, up to 30-foot ROW)

5

Number

23.5

16

0.3

2.2

13.5

7.5

0.7

6.8

Acres

Proposed Action Alternative

Roadway Improvements (All-Weather Road, 40-foot Right-of-Way
[ROW])

PERMANENT IMPACTS

Type of Project

0.3

1.4

0.3

1.4

5

21.7

14.4

0.3

0.6

13.5

7.3

0.5

6.8

BP Hill Improvement
Alternative
Miles
Number
Acres

Table 3-1. Summary of Impacts of Project Components by Alternative

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3-3

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00003777
3-4

1999). This area is also classified as the Yuha Desert Management Area (YDMA) for the FTHL
(Phrynosoma mcallii). The YDMA encompasses approximately 60,000 acres. Approximately
57,200 acres of the YDMA are under Federal ownership. As part of the FTHL Rangewide
Management Strategy, the cumulative new disturbance per management area since 1997 may not
exceed 1 percent of the total management area acreage on Federal lands (i.e., 572 acres).
Other than the presence of the existing border road and BP Hill access road and RVSS site, the
area including and surrounding the project corridor is largely undisturbed (Figure 3-1). IID had
an extant gravel/sand quarry located near the eastern terminus of the project area. This site is
currently not in use and has been returned to the BLM. In general, vacant desert land exists
adjacent to the project corridor in all directions. Agricultural fields, which surround the cities of
Calexico (U.S.) and Mexicali (Mexico), begin approximately 1.6 miles to the east, with the
residential portions of Calexico and the smaller city of Seeley beginning approximately 10 miles
to the east and northeast.
3.2.2 Environmental Consequences
3.2.2.1 No Action Alternative
Under the No Action Alternative, no road improvements or construction would occur; therefore,
no new impacts, either beneficial or adverse, would occur on land use within the project region.
3.2.2.2 Proposed Action Alternative
Through the implementation of the Proposed Action Alternative, moderate impacts on land use
are expected. The permanent disturbance of up to 7.5 acres of the YDMA would occur as a
result of the improvement and construction activities. This amount of disturbance would not
cause the BLM to exceed its cumulative cap of one percent of the total area of the YDMA.
Further, CBP would compensate BLM for all impacts within the YDMA. Land in the immediate
surrounding area would remain uninhabited, and the presence of the proposed roadway would
not have an impact on local agricultural or residential areas.
3.2.2.3 BP Hill Improvement Alternative
Impacts for this alternative would be similar to those outlined for the Proposed Action
Alternative. However, only up to 7.3 acres of YDMA would be permanently disturbed.
3.3

SOILS

3.3.1 Affected Environment
The Imperial Valley, located within the Salton Trough, is a broad, flat, alluvial area that lies
partly below sea level, bounded to the east by branches of the San Andreas Fault and the
Brawley Seismic Zone, and to the west by the San Jacinto-Coyote Creek and Elsinore-Laguna
Salada Faults (Imperial County/BLM 2012).
Soils found in the project area remain unclassified by the Natural Resource Conservation Service
(NRCS) Database; however, soil surveys from similar areas of comparable elevation located
approximately 13 miles to the west classify the soil as Rositas. Rositas soils are very deep,
formed in sand aeolian material, and are somewhat excessively drained with negligible to low
runoff and rapid permeability.
West Desert Road EA

Final
February 2013

·

0

1

2

3

Project Location

4
Miles

Figure 3-1: Land Use Map

"
)

May 2012

Yuha Basin ACEC

Road Improvements

Waived Areas

IID Gravel Pit

3-5
00003778

00003779
3-6

Quaternary lake deposits, alluvium, stream channel deposits, fan deposits, and Pleistocene nonmarine deposits comprise the majority of the material with local origin from the Inkopah and
Jacumba Mountains to the west and south, and from the Coyote Mountains to the north.
3.3.2 Environmental Consequences
3.3.2.1 No Action Alternative
Under the No Action Alternative, soils within the project corridor would remain the same and no
direct impacts would occur. However, possible indirect impacts from the degradation of soils
might occur from the unabated illegal traffic in the project area.
3.3.2.2 Proposed Action Alternative
The road improvements would occur along an extant border road, which has become impassable
due to lack of maintenance and repair efforts. With implementation of the Proposed Action
Alternative, there would be up to 7.5 acres of direct permanent impacts and up to 23.5 acres of
temporary impacts on soils. These soils are common locally and regionally. Therefore, no major
impacts are expected.
Short-term impacts, such as increased runoff, can be expected on soils from the improvement
and construction of the roads; however, these impacts would be alleviated once construction is
finished. Long-term effects on soils would be compaction from vehicles on the roads. Pre- and
post-construction Best Management Practices (BMP) would be developed and implemented to
reduce or eliminate erosion and downstream sedimentation. Compaction techniques and erosion
control measures, such as waterbars, gabions, straw bales, and the use of riprap or sediment
traps, are some of the BMPs that would be implemented to avoid or minimize potential erosion.
Beneficial indirect impacts on soils north of the project corridor due to less disturbance and;
therefore, less compaction and erosion would potentially occur as USBP agents are better able to
detect, deter, and apprehend illegal cross-border violators (CBV) as a result of this alternative.
3.3.2.3 BP Hill Improvement Alternative
Under the BP Hill Improvement Alternative, the impacts on soils would be similar to those
described for the Proposed Action Alternative. However, this alternative would permanently (up
to 7.3 acres) and temporarily (up to 21.7 acres) impact less than the Proposed Action Alternative.
3.4

GEOLOGY

3.4.1 Affected Environment
The project area is located in the Colorado Desert geomorphic province, which was formed as a
depression between the Mojave desert to the east and the peninsular ranges to the west. The
province lies over the sediment-filled valley formed by the southern extension of the San
Andreas Fault system. It covers the extent of the ancient Lake Cahuilla, the current remnant of
which is the Salton Sea to the north. Subsurface rocks are Pleistocene and Recent Quaternary
sediments (California Geological Survey 2002 and 2010). Signal Mountain is an exposed
example of the older, indurated Pleistocene sedimentary rocks.

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00003780
3-7

Groundwater in the region is contained in unconsolidated sands and silts with little to no
horizontal barriers to groundwater flow, which is generally to the south and to the east into the
Colorado River (California Department of Public Works 2004). The depth to groundwater in the
project area is likely over 100 feet below ground surface.
The location of the project area lies over the San Andreas Fault and carries with it the moderately
high probability of large damaging earthquake activity (California Department of Conservation
1999). A recent magnitude-7.2 earthquake occurred in the area in 2010.
3.4.2 Environmental Consequences
3.4.2.1 No Action Alternative
As a result of the No Action Alternative, no impacts on geologic resources would occur, as no
construction or improvement activities would occur.
3.4.2.2 Proposed Action Alternative
Construction, improvement, and operation of the proposed roads would not disturb or impact any
significant geologic resources of importance in the area. Modifications of surface soils and rocks
would not impact groundwater-bearing strata in the area, since the depth to groundwater is
generally over 100 feet below ground surface. Because the project area is located in a known
earthquake hazard zone, there is the potential for any road improvements to be impacted by
future earthquakes, resulting in the need for increased road maintenance and rebuilding of some
road structures.
3.4.2.3 BP Hill Improvement Alternative
The same impacts as described for the Proposed Action Alternative would occur if this
alternative were implemented.
3.5

VEGETATION

3.5.1 Affected Environment
The project area lies in the Lower Colorado River Valley (LCRV) biome of the Sonoran Desert.
The vegetation community is broadly classified as Sonoran Desert scrub (Brown 1994). The
Sonoran Desert is an extremely arid but hot environment. Where water flow has formed arroyos
or channels denser vegetation may form, and outside of these areas that concentrate water
vegetation is much sparser.
Site visits and biological surveys of the project area were conducted on June 28, 2012, and are
described in a Biological Survey Report (CBP 2012) (Appendix B). During meandering
pedestrian surveys, Gulf South Research Corporation (GSRC) biologists noted flora and fauna
observed on-site. The project corridor contained less than five percent groundcover, was highly
disturbed from past human activities, and the dominant plant species observed was creosote
bush, as is typical for this area within the Sonoran Desert (Photograph 3-1 and 3-2).

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00003781
3-8

Photograph 3-1. Vegetation in the project corridor, facing
west.

Photograph 3-2. Facing west with creosote bush in
foreground.

Among the list of 22 plant species observed was desert holly (Atriplex hymenelytra), skeleton
weed (Eriogonum deflexum), white bursage (Ambrosia dumosa), honey mesquite (Prosopis
glandulosa), and catclaw acacia (Acacia greggii). Skeleton weed, honey mesquite, and catclaw
acacia were also observed growing along the intermittent washes found in the project corridor.
Of the species observed in the project corridor, only Sahara mustard (Brassica tournefortii) is
considered to be an invasive plant species (CBP 2012). A complete list of species observed is
included in Appendix B.
3.5.2 Environmental Consequences
3.5.2.1 No Action Alternative
Under the No Action Alternative, no direct impacts would occur on vegetation communities.
However, long-term direct and indirect impacts on vegetation communities would continue and
likely increase as a result of CBV activities that damage vegetation, introduce trash and waste,
and promote the dispersal and establishment of non-native invasive species. The presence of
CBVs and the damage they cause could potentially result in long-term, moderate impacts on
vegetation as a result of disturbance and habitat degradation.
3.5.2.2 Proposed Action Alternative
The Proposed Action Alternative would permanently impact up to 7.5 acres of vegetation.
Permanent impacts on vegetation include the compaction of the natural substrate and destruction
of plants within the road right-of-way (ROW). Additionally, up to 23.5 acres of vegetation
would be temporarily impacted during road improvements and construction and the use of
turnarounds and staging areas.
Permanent and temporary impacts on vegetation during construction activities would be
minimized to the extent practicable through avoidance, minimization, and rehabilitation as
discussed in Section 5.0 of this document. Fugitive dust resulting from construction activities
would have a minimal effect on plant respiration and photosynthesis. Application of wetting
solutions during these activities would further minimize these temporary impacts. Although the
direct impacts would permanently remove up to 7.5 acres of vegetation, the impacted vegetation
communities and their associated plant species are common throughout Imperial County.
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00003782
3-9

Because maintenance and repair activities would be within the permanently disturbed footprint,
no additional impacts would occur.
The effects of the Proposed Action Alternative would not result in the long-term reduction of
population viability for any plant species and would not affect any sensitive or rare vegetation
communities. Therefore, the direct and indirect impacts on vegetation would not be considered
major.
3.5.2.3 BP Hill Improvement Alternative
Under this alternative, vegetation would be permanently and temporarily impacted as described
under the Proposed Action Alternative; however, this alternative would impact less acreage (see
Table 3-1). The Sonoran Desert scrub vegetation community is extremely common in the
vicinity of the project area, and the direct effect of degradation and removal of a total of up to 7.3
acres of vegetation would not have a major adverse effect on vegetation communities in the
region. Indirect effects on vegetation would occur as described in the Proposed Action
Alternative.
3.6

WILDLIFE

3.6.1 Affected Environment
The Sonoran Desert is extremely hot, and many animals are nocturnal. Many of the animals that
inhabit the Sonoran Desert are found throughout the warmer and drier regions of the
southwestern United States (Brown 1994). Common mammals include multiple species of bat,
coyote (Canis latrans), black-tailed jack-rabbit (Lepus californicus), desert cottontail (Sylvilagus
audubonii), Merriam’s kangaroo rat (Dipodomys merriami), white-throated woodrat (Neotoma
albigula), and desert pocket mouse (Chaetodipus penicillatus). Less common mammals, like the
desert kangaroo rat (Dipodomys deserti), Bailey’s pocket mouse (Chaetodipus baileyi), and
round-tailed ground squirrel (Spermophilus tereticaudus), have more limited distributions and
are more specifically characteristic of Sonoran Desert habitats (Brown 1994).
The project corridor is located in a migratory flyway. Raptors, waterbirds such as brown pelican
(Pelecanus occidentalis) and cormorant (Phalacrocoracidae sp.), as well as shorebirds including
mountain plover (Charadrius montanus) and snowy plover (Charadrius nivosus) migrate
through the desert habitat between the Gulf of Mexico and the Salton Sea. Common birds
include the road runner (Geococcyx californianus), mourning dove (Zenaida macroura), lesser
nighthawk (Chordeiles acutipennis), cactus wren (Campylorhynchus brunneicapillus), blacktailed gnatcatcher (Polioptila melanura), phainopepla (Phainopepla nitens), black-throated
sparrow (Amphispiza bilineata), Gambel’s quail (Callipepla gambelii), and northern flicker
(Colaptes auratus) (Brown 1994). Although less abundant, raptors can be common in
semidesert grasslands or croplands, and scavengers can be observed throughout the Sonoran
Desert. Less than two miles east of the project area are large expanses of irrigated cropland that
could attract or concentrate bird species, which may occasionally wander into the project area.

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00003783
3-10

The diverse reptilian fauna in this habitat of the western Sonoran Desert includes desert iguana
(Dipsosaurus doorsalis), desert spiny lizard (Sceloporus magister), Colorado fringed-toed lizard
(Uma notata), Colorado desert sidewinder (Crotalus cerastes laterorepens), rosy boa (Lichanura
trivirgata), and western shovelnose snake (Chionactis occipitalis).
Wildlife observed during biological surveys of the project area included mourning dove, lesser
nighthawk, black-throated sparrow, tiger whiptail (Aspidoscelis tigris), and long-tailed brush
lizard (Urosuarus graciosus) (CBP 2012). Although not observed during the surveys, tracks
and/or scat were identified within the project corridor for the following species: FTHL, desert
kangaroo rat, coyote, kit fox (Vulpes macrotis), and sidewinder (Crotalus cerastes) (CBP 2012).
The FTHL is currently being managed by an Interagency Coordinating Committee (ICC)
following the species listing as Category 2, Candidate for listing as a threatened or endangered
species by the USFWS and a candidate species by the CDFG Commission and subsequent
lawsuits. The project is located within one of three management areas in Imperial County
managed by BLM. The YDMA was established because it was of sufficient area and habitat
quality to maintain a self-sustaining FTHL population. Ongoing monitoring of the species has
been conducted in the YDMA for many years. Surveys include an established demographic plot
in fairly close proximity to the proposed project. Other monitoring efforts include occupancy
surveys that represent 45 established plots in the Yuha Desert. The ICC reports annually on
results of the monitoring efforts and authorized impacts within the management areas.
3.6.2 Environmental Consequences
3.6.2.1 No Action Alternative
Under the No Action Alternative, no direct impacts on wildlife or wildlife habitat would occur.
However, off-road CBV activity and required interdiction actions would continue to degrade
wildlife habitat. This degradation of vegetation communities could potentially impact wildlife
through a loss of cover, forage, nesting, and other opportunities, and potentially a loss of suitable
habitat over large areas if wildfires are ignited. Off-road vehicle and pedestrian traffic would
continue to disturb wildlife species, cause fauna to avoid areas of high illegal traffic volume, and
disturb or degrade wildlife habitat.
3.6.2.2 Proposed Action Alternative
Under the Proposed Action, up to 7.5 acres of Yuha Desert ACEC habitat would be directly and
permanently impacted and cleared of vegetation. Less mobile individuals such as lizards,
snakes, or mice could be impacted as tunnels and burrows collapse during road improvements
and construction. During construction most wildlife, however, would presumably avoid direct
harm by escaping into surrounding habitat where individuals would be forced to compete with
other fauna for food, water, and shelter resources.
Disturbance from construction noise and presence of equipment and people would also impact
wildlife. The effects of these disturbances on wildlife would include temporary avoidance of
work areas and increased competition for unaffected resources. Due to the limited extent and
duration of construction activities, the impacts would be minor. Mitigation measures, including
pre-construction surveys for nesting migratory birds, would reduce construction-related impacts;
these measures are outlined in Section 5.0 of this EA.
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Once the project is complete, the road would be more accessible and frequently used by CBP.
The increased use would disturb wildlife, which may seek areas with less human activity.
The Proposed Action could result in indirect and long-term beneficial impacts on wildlife by
reducing the adverse impacts of CBV activity and the resulting law enforcement response.
Direct impacts from off-road enforcement actions would be reduced as agents use the designated
and improved roadway.
3.6.2.3 BP Hill Improvement Alternative
With the implementation of the BP Hill Alternative, impacts would be similar to those described
for the Proposed Action Alternative.
3.7

THREATENED AND ENDANGERED SPECIES

3.7.1 Affected Environment
The ESA protects endangered and threatened species, as well as the habitat upon which they
depend for their survival. Federal agencies are required to implement protective measures to
avoid or mitigate effects on listed species and to further the purposes of the ESA whenever
practicable. The Secretary of the Interior is responsible for the listing of species and
development of recovery plans. USFWS is the primary agency responsible for implementing the
ESA and is responsible for birds, terrestrial species, and freshwater species. The USFWS
responsibilities under the ESA include (1) the identification of threatened and endangered
species; (2) the identification of critical habitats for listed species; (3) implementation of research
on, and recovery efforts for, these species; and (4) consultation with other Federal agencies
concerning measures to avoid harm to listed species.
An endangered species is a taxonomic group officially recognized by the USFWS as being in
danger of extinction throughout all or a significant portion of its range. A threatened species is a
taxonomic group likely to become endangered within the foreseeable future throughout all or a
significant portion of its range. Proposed species are those that have been formally submitted to
Congress for official listing as threatened or endangered. Species may be considered endangered
or threatened when any of the five following criteria occur: (1) current/imminent destruction,
modification, or curtailment of their habitat or range; (2) overuse of the species for commercial,
recreational, scientific, or educational purposes; (3) disease or predation; (4) inadequacy of
existing regulatory mechanisms; and (5) other natural or human-induced factors affecting
continued existence.
In addition, the USFWS has identified species that are candidates for listing as a result of
identified threats to their continued existence. The candidate designation includes those species
for which the USFWS has sufficient information to support proposals to list as endangered or
threatened under the ESA. However, proposed rules have not yet been issued because such
actions are precluded at present by other listing activity. Although not afforded protection by the
ESA, candidate species may be protected under other Federal or state laws.
Biological surveys of the project area were conducted by GSRC on June 28, 2012. No Federally
listed or state-listed species were observed during the biological surveys. However, scat and
tracks from FTHL, which is a conservation species, were observed within the project corridor.
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3.7.1.1 Federal
Four Federally listed species may potentially occur near the project corridor or similar habitat in
Imperial County, California (Table 3-2, Appendix C) (USFWS 2012). Of these four species,
none have the potential to occur in the project area because no suitable habitat for any of the
listed species is located in the project corridor.
Table 3-2. Federally Listed Species for Imperial County, California
Common/Scientific
Name
BIRDS
Least Bell’s vireo
(Vireo bellii pusillus)

Federal
Status

Endangered

Southwestern willow
flycatcher
(Empidonax traillii
extimus)

Endangered;
Proposed
Critical
Habitat

Yuma clapper rail
(Rallus longirostris
yumanensis)

Endangered

Habitat

Inhabits dense shrubs and trees along
riparian corridors.
Inhabits riparian forests, oak (Quercus spp.)
woodlands, and shrub willow (Salix spp.)
patches along high-elevation streams and
meadows, and broad-leaf deciduous forest
along desert washes and streams.
Inhabits freshwater marshes containing dense
stands of cattail (Typha spp.) and bulrush
(Juncus spp.), and mature stands of emergent
vegetation along margins of shallow ponds
with stable water levels.

Potential to Occur
in the Proposed
Project Area
No

No

No

MAMMALS
Peninsular bighorn
sheep
(Ovis Canadensis ssp.
Nelson)

Endangered;
Critical
Habitat

Steep terrain that allows escape from
predators and has a high variation in slope
and aspect. Also known from alluvial fans,
valleys linking mountain chains, and washes
with browse plants.

No

Source: USFWS 2012

3.7.1.2 Critical Habitat
The ESA also calls for the conservation of designated “Critical Habitat” – the areas of land,
water, and air space that an endangered species requires for survival. Critical Habitat also
includes such things as food and water sources, breeding sites, cover or shelter, and sufficient
habitat area to provide for normal population growth and behavior. One of the primary threats to
many species is the destruction, conversion, or modification of essential habitat by uncontrolled
land and water development.
Two of the four Federally-listed species have designated Critical Habitat. They are the
southwestern willow flycatcher and peninsular bighorn sheep (see Table 3-2). No Critical
Habitat occurs within or adjacent to the project area, and the closest designated Critical Habitat is
for peninsular bighorn sheep approximately 15 miles to the west (USFWS 2009).
3.7.1.3 State
The CDFG maintains a list of species that are state-listed as rare, threatened, or endangered
(CDFG 2012). This list is available in Appendix C and includes 14 animal and 3 plant species
that could occur in Imperial County, California. These species are not necessarily the same as

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those protected under the ESA. No individuals or habitat for any of the state-listed threatened or
endangered species were observed during biological surveys.
3.7.1.4 BLM Sensitive Species
The BLM publishes a list of special status plants and animals which includes BLM sensitive
species on lands in the BLM El Centro district of California, where the project area lies, and
those lists are provided in Appendix C. Many of these are also listed by the Federal government
or the State of California.
Although no Federally listed or state-listed species were observed during the biological surveys,
FTHL was recorded in the project corridor. The FTHL is a BLM sensitive species. In addition,
five Federal agencies (including BLM) signed a Memorandum of Agreement to protect the
FTHL and its habitat on Federal lands. The Strategy specifies compensatory mitigation for
ground disturbing impacts within FTHL management areas.
One burrow complex, presumably inhabited by desert kangaroo rats, that could provide habitat
for the BLM-listed western burrowing owl (Athene cunicularia) and kit fox (Vulpes macrotis)
was observed and recorded during the June 2012 survey efforts (CBP 2012). The kit fox,
burrowing owl, and badger (Taxidea taxus) may occur in the project area, and the BLM indicated
that these species are of growing concern to CDFG and to area natural resource managers.
3.7.2 Environmental Consequences
3.7.2.1 No Action Alternative
Under the No Action Alternative, no direct impacts on threatened or endangered species or their
habitats would occur. However, the direct and long-term impacts of CBV and consequent law
enforcement activities throughout the project area and surrounding areas would continue to
threaten listed species and their habitats. CBV activities create trails, damage vegetation,
promote the dispersal and establishment of invasive species, and can result in catastrophic wild
fires. These actions have an indirect adverse impact on threatened and endangered plant species
by causing harm to individuals and degrading their habitat.
The presence of CBVs and resulting law enforcement activities can disturb sensitive animal
species, result in their temporary displacement from vital resources, and potentially result in the
loss of individuals due to heightened response and exertion, particularly when exposed to high
daytime temperatures. The degree of this impact would be dependent on environmental stressors
(i.e., drought, season), the health of the animal, and the duration and frequency of disturbances.
3.7.2.2 Proposed Action Alternative
Under the Proposed Action Alternative, there would be no adverse effects on Federally listed or
state-listed threatened and endangered species or their habitats, as none exist within the project
area. However, long-term, beneficial effects would occur by lessening impacts of CBV activity
on habitats throughout the project area and surrounding desert.
The Proposed Action would potentially impact the habitat of four BLM sensitive species: the
western burrowing owl, FTHL, kit fox, and badger. Although potential habitat for the western
burrowing owl, kit fox, and badger would be impacted, these species were not observed during
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recent biological surveys, and the habitat for these species is both locally and regionally
common. Biological monitors would be on-site during construction activities, if a western
burrowing owl, kit fox, or badger is seen occupying a burrow or structure in the project area,
CDFG recommended buffers would be established until the animal has left the project area.
Therefore, any potential impacts would not be considered major.
FTHL habitat would be impacted by the construction activities, and there is the potential for
taking individuals. BMPs discussed in Section 5.0 of this document, such as preconstruction
surveys and monitoring for the presence of the FTHL during construction activities, as well as
compensation for loss of habitat, would reduce the impacts on FTHL. When these BMPs are
combined with the fact that there is an abundance of habitat for the FTHL both locally and
regionally, no major impacts would occur as a result of the Proposed Action Alternative.
3.7.2.3 BP Hill Improvement Alternative
The BP Hill Alternative would have the same impacts on protected species as discussed under
the Proposed Action Alternative.
3.8

WATER RESOURCES

3.8.1 Affected Environment
Water quality for designated beneficial uses is protected by the state and should work in tandem
with sections 303 and 305 of the Clean Water Act (CWA).
3.8.1.1 Surface Waters
The proposed project area falls within the Colorado River Basin Hydrologic Region (HR) Unit, 1
of 10 hydrologic regions in California that correspond to major watersheds and drainage areas
managed by the California Department of Water Resources. As the Proposed Action project area
is located within the Colorado River Basin HR, actions within the area are subject to the
management directives of the Water Quality Control Plan (Basin Plan) for the Imperial Valley
Planning Area, under the jurisdiction of the Colorado River Basin RWQCB.
The Colorado River provides the dominant water source for the area, with water transported via
the All-American Canal. Approximately 3.1 million acre-feet of Colorado River water is
diverted through the All-American Canal annually (Alles 2011). Surface waters in the area are
predominantly used for irrigation, industrial, and domestic purposes (RWQBC 2006). Other
surface waters are located several miles to the northeast and east of the project corridor and
include the Salton Sea, the Alamo River, the New River, and the Dixie Drain, which runs
adjacent to and drains agriculture fields in western Calexico. There are several other smaller
canals in the surrounding area that provide irrigation for agricultural purposes.
3.8.1.2 Groundwater
Groundwater in southern California is supplied from two aquifers: the Basin-Fill and the
Alluvium and Older Sediments (INS 2001). The project corridor lies within the Coyote Wells
Valley Groundwater Basin, which covers approximately 64,000 acres. The depth to groundwater
in the project area is likely over 100 feet below ground surface (California Department of Public
Works 2004). Common sources of contamination of groundwater include irrigation return flow,
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application of pesticides, improper waste disposal, and untreated wastewater. The general
quality of the aquifer is low, with data indicating bicarbonate-chloride as the dominant
compound. The total recharge to this basin is principally derived from percolation of
precipitation on the valley and ephemeral runoff from the surrounding mountains. Unconfined
shallow groundwater exists in parts of the basin, but logs indicate confined groundwater
conditions for several wells drilled near Ocotillo and Coyote Wells (CDWR 2004).
3.8.1.3 Waters of the United States and Wetlands
Section 404 of the CWA of 1977 (P.L. 95-217) authorizes the Secretary of the Army, acting
through the USACE, to issue permits for the discharge of dredged or fill material into Waters of
the U.S., including wetlands. Waters of the U.S. (Section 328.3[2] of the CWA) are those waters
used in interstate or foreign commerce, subject to ebb and flow of tide, and all interstate waters
including interstate wetlands. Waters of the U.S. are further defined as all other waters such as
intrastate lakes, rivers, streams, mudflats, sandflats, wetlands, sloughs, prairie potholes, wet
meadows, playa lakes, natural ponds or impoundments of waters, tributaries of waters, and
territorial seas. Jurisdictional boundaries for Waters of the U.S. are defined in the field as the
ordinary high water mark, which is that line on the shore or bank established by the fluctuations
of water and indicated by physical characteristics such as clear, natural lines impressed on the
bank, shelving, changes in the character of soil, destruction of terrestrial vegetation, the presence
of litter and debris, or other appropriate means that consider the characteristics of the
surrounding areas. Wetlands are those areas inundated or saturated by surface or groundwater at
a frequency and duration sufficient to support, and that under normal circumstances do support, a
prevalence of vegetation typically adapted for life in saturated soil conditions (USACE 1987).
Waters of the U.S. do occur as ephemeral drainages throughout the project corridor, and the
survey identified six ephemeral washes bisecting the project corridor that could potentially be
regulated as Waters of the U.S. (Figure 3-2). The total impact on the six potential Waters of the
U.S. is less than 0.2 acre. Additionally, no wetlands were observed during the biological survey
on June 28, 2012.
3.8.2 Environmental Consequences
3.8.2.1 No Action Alternative
Implementation of the No Action Alternative would not result in any impacts on surface waters,
groundwater, or Waters of the U.S.
3.8.2.2 Proposed Action Alternative
Water for construction use would be trucked on site and delivered via water truck. It is estimated
that 7.8 acre-feet of water (4.9 acre-feet per mile) would be needed for construction purposes.
The water would either be provided from the All-American Canal or through a privately
permitted water supplier. The one-time use of water from the All-American Canal could result
in a temporary reduction of available water in the region; however, this reduction is de minimis
when in comparison to the volume of water (i.e., 3.1 million acre-feet per year) flowing through
the canal. Also, any water obtained from a private contractor would be from permitted wells that
are allowed to withdraw set volumes. This minor extraction would have no measurable impact
on the water quality or quantity of the region. BMPs to minimize the potential for runoff and
sedimentation of the ephemeral washes would also be incorporated into the design of the project.
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Project Location

Figure 3-2: Waters of the U.S. within the Project Area

·

0

500

1,000

1,500
Feet

Potential Waters of the U.S.

"
)

Road Improvements

May 2012

Waived Staging Area

)
"

Waived Areas

Staging Area (50ft x 50ft)

j
k

3-16
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A Stormwater Pollution Prevention Plan (SWPPP) will also be developed and implemented to
ensure long-term recovery of the area and to prevent major soil erosion problems.
The Proposed Action Alternative would not result in a permanent impact on any perennial or
intermittent streams, as none are present within the project corridor. As mentioned above, six
potential jurisdictional ephemeral Waters of the U.S. were identified during field surveys within
the project corridor. The six ephemeral washes that are Waters of the U.S. would be traversed
using concrete low-water crossings, reinforced concrete pipes, box culverts, or bridges. The
expected total impact on those Waters of the U.S. is less than 0.2 acre. The impacted areas
associated with these washes range from 0.004 to 0.1 acre. Therefore, each of the crossings
would meet the threshold (0.5 acre) for authorization under Section 404 Nationwide Permit 14.
Since each has independent utility, each crossing would be considered a single and complete
project. Additionally, since all of the Waters of the U.S. crossings do not exceed 0.1 acre these
road improvement and construction actions would not require notifying the USACE; however, a
Section 401 Water Quality Certification would be obtained from the RWQCB.
The Proposed Action Alternative would not impact any surface water resource sites with the
installation of the proposed roadway. Proper maintenance of construction equipment and the use
of BMPs during construction activities would minimize the possibility of accidental spills of
petroleum, oil, and lubricants (POL) that, if they occurred, could affect surface water and
groundwater quality. Operation and maintenance of the proposed roadways would have no
effect on the region’s surface water or groundwater supplies and/or quality.
3.8.2.3 BP Hill Improvement Alternative
Under this alternative, the impacts on surface waters, groundwater, or Waters of the U.S. would
be the same as those described for the Proposed Action Alternative.
3.9

AIR QUALITY

3.9.1 Affected Environment
The U.S. Environmental Protection Agency (USEPA) established National Ambient Air Quality
Standards (NAAQS) for specific pollutants determined to be of concern with respect to the
health and welfare of the general public. Ambient air quality standards are classified as either
"primary" or "secondary." The major pollutants of concern, or criteria pollutants, are carbon
monoxide (CO), sulfur dioxide (SO2), nitrogen dioxide (NO2), ozone (O3), particulate matter less
than 10 microns (PM-10), particulate matter less than 2.5 microns (PM-2.5), and lead (Pb).
NAAQS represent the maximum levels of background pollution that are considered safe, with an
adequate margin of safety, to protect the public health and welfare. The NAAQS are included in
Table 3-3.
Areas that do not meet these NAAQS standards are called non-attainment areas; areas that meet
both primary and secondary standards are known as attainment areas. The Federal Conformity
Final Rule (40 CFR Parts 51 and 93) specifies criteria or requirements for conformity
determinations for Federal projects. The Federal Conformity Rule was first promulgated in 1993
by the USEPA, following the passage of Amendments to the Clean Air Act in 1990. The rule
mandates that a conformity analysis must be performed when a Federal action generates air
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pollutants in a region that has been designated a non-attainment or maintenance area for one or
more NAAQS.
Table 3-3. National Ambient Air Quality Standards
Primary Standards

Pollutant
Carbon
Monoxide

Level

Averaging Time
3

9 ppm (10 mg/m )
35 ppm (40 mg/m3)

Lead

0.15 g/m3 (2)
3

1.5 g/m
Nitrogen Dioxide

53 ppb

(3)

100 ppb
Particulate
Matter (PM-10)
Particulate
Matter (PM-2.5)

Ozone

3

150 g/m

15.0 g/m3
35 g/m3
0.075 ppm
(2008 std)
0.08 ppm
(1997 std)
0.12 ppm
0.03 ppm

Sulfur Dioxide

Secondary Standards

0.14 ppm
75 ppb (11)

Level

Averaging Times

(1)

8-hour
1-hour (1)
Rolling 3-Month
Average
Quarterly Average
Annual
(Arithmetic Average)
1-hour (4)
24-hour

(5)

Annual (6)
(Arithmetic Average)
24-hour (7)

None
Same as Primary
Same as Primary
Same as Primary
None
Same as Primary
Same as Primary
Same as Primary

(8)

Same as Primary

8-hour (9)

Same as Primary

(10)

Same as Primary

8-hour

1-hour
Annual
(Arithmetic Average)
24-hour (1)
1-hour

3-hour (1)

0.5 ppm
None

Source: USEPA 2012a at http://www.epa.gov/air/criteria.html
Units of measure for the standards are parts per million (ppm) by volume, parts per billion (ppb - 1 part in 1,000,000,000) by
volume, milligrams per cubic meter of air (mg/m3), and micrograms per cubic meter of air ( g/m3).
(1)
Not to be exceeded more than once per year.
(2)
Final rule signed October 15, 2008.
(3)
The official level of the annual NO2 standard is 0.053 ppm, equal to 53 ppb, which is shown here for the purpose of clearer
comparison to the 1-hour standard
(4)
To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average at each monitor within
an area must not exceed 100 ppb (effective January 22, 2010).
(5)
Not to be exceeded more than once per year on average over 3 years.
(6)
To attain this standard, the 3-year average of the weighted annual mean PM2.5 concentrations from single or multiple
community-oriented monitors must not exceed 15.0 g/m3.
(7)
To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor
within an area must not exceed 35 g/m3 (effective December 17, 2006).
(8)
To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured
at each monitor within an area over each year must not exceed 0.075 ppm (effective May 27, 2008).
(9)
(a) To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations
measured at each monitor within an area over each year must not exceed 0.08 ppm.
(b) The 1997 standard—and the implementation rules for that standard—will remain in place for implementation purposes as
EPA undertakes rulemaking to address the transition from the 1997 ozone standard to the 2008 ozone standard.
(c) EPA is in the process of reconsidering these standards (set in March 2008).
(10)
(a) EPA revoked the 1-hour ozone standard in all areas, although some areas have continuing obligations under that standard
("anti-backsliding").
(b) The standard is attained when the expected number of days per calendar year with maximum hourly average
concentrations above 0.12 ppm is < 1.
(11)
(a) Final rule signed June 2, 2010. To attain this standard, the 3-year average of the 99th percentile of the daily maximum 1hour average at each monitor within an area must not exceed 75 ppb.

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A conformity analysis is the process used to determine whether a Federal action meets the
requirements of the General Conformity Rule. It requires the responsible Federal agency to
evaluate the nature of a proposed action and associated air pollutant emissions and calculate
emissions as a result of the proposed action. If the emissions exceed established limits, known as
de minimis thresholds, the proponent is required to implement appropriate mitigation measures.
Both the Federal government and the State of California monitor air quality in California. The
USEPA classifies Imperial County as a moderate non-attainment area for 8-hour ozone, serious
non-attainment for PM-10, and moderate non-attainment of PM-2.5 (EPA 2012b). California
Air Resources Board (CARB) classifies Imperial County as in non-attainment for ozone, PM-2.5
and PM-10 (CARB 2010). Table 3-4 presents a summary of attainment and maintenance status
for NAAQS and California Ambient Air Quality Standards (CAAQS) in Imperial County.
Table 3-4. NAAQS and CAAQS Air Quality Status in Imperial County
Pollutant
O3
CO
PM-10
PM-2.5
NO2
SO2
Pb
Sulfates
Hydrogen Sulfide
Visibility-Reducing Particles

Federal Designation

State Designation

Non-attainment (Moderate)
Attainment
Non-Attainment (Serious)
Non-attainment (Moderate)
Attainment
Attainment
Attainment
No Federal standard
No Federal standard
No Federal standard

Non-attainment
Attainment
Non-attainment
Non-attainment
Attainment
Attainment
Attainment
Attainment
Unclassified
Unclassified

Source: USEPA 2012b and CARB 2012

3.9.1.1 Greenhouse Gases and Climate Change
Global climate change refers to a change in the average weather on the earth. Greenhouse gases
(GHG) are gases that trap heat in the atmosphere. They include water vapor, carbon dioxide
(CO2), methane (CH4), nitrous oxide (N2O), fluorinated gases including chlorofluorocarbons
(CFC) and hydrochlorofluorocarbons (HFC), and halons, as well as ground-level O3 (California
Energy Commission 2007).
The major GHG-producing sectors in society include transportation, utilities (e.g., coal and gas
power plants), industry/manufacturing, agriculture, and residential. End-use sector sources of
GHG emissions include transportation (40.7 percent), electricity generation (22.2 percent),
industry (20.5 percent), agriculture and forestry (8.3 percent), and other (8.3 percent) (California
Energy Commission 2007). The main sources of increased concentrations of GHG due to human
activity include the combustion of fossil fuels and deforestation (CO2), livestock and rice
farming, land use and wetland depletions, landfill emissions (CH4), refrigeration system and fire
suppression system use and manufacturing (CFC), and agricultural activities, including the use of
fertilizers (California Energy Commission 2007).
Final Mandatory GHG Inventory Rule
In response to the Consolidation Appropriations Act (House Resolution 2764; PL 110–161),
USEPA has issued the Final Mandatory Reporting of Greenhouse Gases Rule. The rule requires
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large sources that emit 25,000 metric tons (27,557 U.S. tons) or more per year of GHG emissions
to report GHG emissions in the United States, collect accurate and timely emissions data to
inform future policy decisions, and submit annual GHG reports to the USEPA. The final rule
was signed by the Administrator on September 22, 2009, published on October 30, 2009, and
made effective December 29, 2009.
GHG Threshold of Significance
CEQ drafted guidelines for determining meaningful GHG decision-making analysis. The CEQ
guidance states that if the Project would be reasonably anticipated to cause direct emissions of
25,000 metric tons (27,557 U.S. tons) or more of CO2 GHG emissions on an annual basis,
agencies should consider this a threshold for decision makers and the public. CEQ does not
propose this as an indicator of a threshold of significant effects, but rather as an indicator of a
minimum level of GHG emissions that may warrant some description in the appropriate NEPA
analysis for agency actions involving direct emissions of GHG (CEQ 2010).
The GHG covered by EO 13514 are CO2, CH4, N2O, HFC, perfluorocarbons, and sulfur
hexafluoride. These GHG have varying heat-trapping abilities and atmospheric lifetimes. CO2
equivalency (CO2e) is a measuring methodology used to compare the heat-trapping impact from
various greenhouse gases relative to CO2. Some gases have a greater global warming potential
than others. Nitrous oxides (NOx), for instance, have a global warming potential that is 310
times greater than an equivalent amount of CO2, and CH4 is 21 times greater than an equivalent
amount of CO2 (USEPA 2010).
3.9.2 Environmental Consequences
3.9.2.1 No Action Alterative
The No Action Alternative would not result in any direct impacts on air quality because there
would be no construction activities. However, fugitive dust emissions created by illegal off-road
vehicle traffic and resulting law enforcement actions and vehicle traffic would continue and
likely increase. These fugitive dust emissions would continue to adversely affect the air quality
of the region.
3.9.2.2 Proposed Action Alternative
Temporary and minor increases in air pollution would occur from the use of construction
equipment (combustion emissions) and the disturbance of soils (fugitive dust) during
construction. The following paragraphs describe the methodologies used to estimate air
emissions produced by the construction activities.
Fugitive dust emissions were calculated using USEPA’s preferred emission factor of 0.19 ton per
acre per month (Midwest Research Institute 1996), which is a more current standard than the
1985 PM-10 emission factor of 1.2 tons per acre-month presented in AP-42 Section 13
Miscellaneous Sources 13.2.3.3 (USEPA 2001).
NONROAD2008a model was used to estimate air emissions from construction equipment. It is
USEPA’s preferred model for estimating emissions from non-road sources (USEPA 2009a).
Combustion emission calculations were made for standard construction equipment, such as a

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backhoe, bulldozer, dump truck, and cement truck. Assumptions were made regarding the total
number of days and hours each piece of equipment would be used.
Construction workers would temporarily increase the combustion emissions in the airshed during
their commute to and from the project area. Emissions from trucks delivering materials such as
cement, fill, and supplies would also contribute to the overall air emission budget. Emissions
from delivery trucks and construction worker commuters traveling to the job site were calculated
using USEPA’s preferred on-road vehicle emission model MOVES2010a (USEPA 2009b).
The total air quality emissions from the construction activities were calculated and compared to
the de minimis thresholds of the General Conformity Rule. Summaries of the total emissions for
construction activities are presented in Table 3-5. Details of the conformity analyses are
presented in Appendix D.
Table 3-5. Total Air Emissions (tons/year) from the Proposed Action Construction versus
the de minimis Threshold Levels-Imperial County
Pollutant
CO
Volatile Organic Compounds (VOC)
Nitrous Oxides (NOx)
PM-10
PM-2.5
SO2
CO2 and CO2 equivalents

Total
(tons/year)

de minimis Thresholds
(tons/year) 1
9.52
6.23
16.36
5.91
1.74
1.92
6,338

100
100
100
70
100
100
27,557

Source: 40 CFR 51.853 and Gulf South Research Corporation (GSRC) model projections.
1
Note that Imperial County is in non-attainment for Ozone, PM-10 (serious), and PM 2.5 (USEPA 2010 and CARB 2012).

Several sources of air pollutants would contribute to the overall air impacts of the construction
project. The air results in Table 3-5 included emissions from the following sources.
Combustion engines of construction equipment
Construction workers commuting to and from work
Supply trucks delivering materials to construction site
Fugitive dust from job-site ground disturbances
As can be seen from the tables above, the proposed construction and operational activities do not
exceed Federal de minimis thresholds for NAAQS, CAAQS, and GHG and, thus, would not
require a Conformity Determination. As there are no violations of air quality standards and no
conflicts with the state implementation plans, the impacts on air quality from the implementation
of the Proposed Action would not be major. BMPs would be incorporated to ensure that fugitive
dust and other air quality constituent emission levels do not rise above the minimum threshold as
required per 40 CFR 51.853(b)(1), and are located in Section 5.8.

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3.9.2.3 BP Hill Improvement Alternative
Under the BP Hill Improvement Alternative, the total air quality emissions from the construction
activities would be similar to those calculated for the Proposed Action Alternative. The
proposed construction and operational activities would not be expected to exceed Federal de
minimis thresholds for NAAQS, CAAQS, and GHG and, similar to the Proposed Action
Alternative, would not require a Conformity Determination. As there are no violations of air
quality standards and no conflicts with the state implementation plans, the impacts on air quality
from the implementation of this alternative would be minor. BMPs would be utilized to ensure
that emission levels are below Federal minimum thresholds.
3.10

NOISE

3.10.1 Affected Environment
Noise is generally described as unwanted sound, which can be based either on objective effects
(i.e., hearing loss, damage to structures, etc.) or subjective judgments (e.g., community
annoyance). Sound is usually represented on a logarithmic scale with a unit called the decibel
(dB). Sound on the decibel scale is referred to as sound level. The threshold of human hearing
is approximately 3 dB, and the threshold of discomfort or pain is around 120 dB. The Aweighted decibel (dBA) is a measurement of sound pressure adjusted to conform with the
frequency response of the human ear. The dBA metric is most commonly used for the
measurement of environmental and industrial noise.
Noise levels occurring at night generally produce a greater annoyance than do the same levels
occurring during the day. It is generally agreed that people perceive intrusive noise at night as
being 10 dBA louder than the same level of intrusive noise during the day, at least in terms of its
potential for causing community annoyance. This perception is largely because background
environmental sound levels at night in most areas are also about 10 dBA lower than those during
the day.
Long-term noise levels are computed over a 24-hour period and adjusted for nighttime
annoyances to produce the day-night average sound level (DNL). DNL is the community noise
metric recommended by the USEPA and has been adopted by most Federal agencies (USEPA
1974). A DNL of 65 dBA is the level most commonly used for noise planning purposes and
represents a compromise between community impact and the need for activities like
construction.
Residential Neighborhoods
Acceptable noise levels have been established by the U.S. Department of Housing and Urban
Development (HUD) for construction activities in residential areas (HUD 1984):
Acceptable (not exceeding 65 dBA) – The noise exposure may be of some concern, but
common building construction will make the indoor environment acceptable, and the
outdoor environment will be reasonably pleasant for recreation and play.

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Normally Unacceptable (above 65 but not greater than 75 dBA) – The noise exposure is
significantly more severe; barriers may be necessary between the site and prominent
noise sources to make the outdoor environment acceptable; special building construction
may be necessary to ensure that people indoors are sufficiently protected from outdoor
noise.
Unacceptable (greater than 75 dBA) – The noise exposure at the site is so severe that the
construction costs to make the indoor noise environment acceptable may be prohibitive,
and the outdoor environment would still be unacceptable.
Noise Attenuation
As a general rule of thumb, noise generated by a stationary noise source, or “point source,” will
decrease by approximately 6 dBA over hard surfaces and 9 dBA over soft surfaces for each
doubling of the distance. For example, if a noise source produces a noise level of 85 dBA at a
reference distance of 50 feet over a hard surface, then the noise level would be 79 dBA at a
distance of 100 feet from the noise source, 73 dBA at a distance of 200 feet, and so on. To
estimate the attenuation of the noise over a given distance, the following relationship is utilized:
Equation 1: dBA2 = dBA1 – 20 log (d2/d1)
Where:
dBA2 = dBA at distance 2 from source (predicted)
dBA1 = dBA at distance 1 from source (measured)
d2 = Distance to location 2 from the source
d1 = Distance to location 1 from the source
Source: California Department of Transportation (Caltrans) 1998

The project corridor is located in a rural area and the closest sensitive noise receptor is a
residential home located approximately 2.2 miles north of the project corridor.
3.10.2 Environmental Consequences
3.10.2.1 No Action Alternative
Under the No Action Alternative, the sensitive noise receptors and wildlife near the proposed
project site would not experience construction noise emissions; however, noise emissions
associated with CBV off-road travel and consequent law enforcement actions would be longterm and minor, and would continue under the No Action Alternative.
3.10.2.2 Proposed Action Alternative
Construction Noise
The proposed construction activities would require the use of common construction equipment.
Table 3-6 presents noise emission levels for construction equipment expected to be used during
the proposed construction activities. Anticipated sound levels at 50 feet from various types of
construction equipment range from 76 dBA to 84 dBA, based on data from the Federal Highway
Administration (FHWA) 2007.

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Table 3-6. A-Weighted (dBA) Sound Levels of Construction Equipment
and Modeled Attenuation at Various Distances1
Noise Source
Backhoe
Dump Truck
Excavator
Concrete mixer truck
Bulldozer
Front-end loader

50 feet

100 feet
78
76
81
79
84
82

200 feet
72
70
75
73
78
76

66
64
69
67
72
70

500 feet

1000 feet
58
56
61
59
64
62

51
49
54
52
57
55

Source: FHWA 2007
1
The dBA at 50 feet is a measured noise emission. The 100- to 1,000-foot results are GSRC modeled estimates.

Construction would involve the use of a bulldozer, which has a noise emission level of 84 dBA
at 50 feet from the source. Assuming the worst case scenario, the noise model (Caltrans 1998)
estimates that noise emissions of 84 dBA would have to travel 450 feet before they would
attenuate to an acceptable level of 65 dBA. To achieve an attenuation of 84 dBA to a normally
unacceptable level of 75 dBA, the distance from the noise source to the receptor would need to
be 140 feet. The closest sensitive noise receptor near the project corridor is over 11,000 feet
away; therefore, the noise impacts from construction activities would be considered negligible.
3.10.2.3 BP Hill Improvement Alternative
Impacts as a result of this alternative would be the same as those described for the Proposed
Action Alternative.
3.11

CULTURAL, HISTORICAL, AND ARCHAEOLOGICAL RESOURCES

3.11.1 Affected Environmental
3.11.1.1 Current Investigations
Prior to fieldwork, GSRC conducted a search of records on file at South Coastal Information
Center of the California Historic Resources Information System at San Diego State University.
Previous investigations and known cultural resources within a 1-mile radius of the project area
were also cross-checked with records at the BLM El Centro Field Office. The review of cultural
resources records indicates that 33 known previous projects were conducted within 1-mile
surrounding the project corridor. These investigations have resulted in the identification of 39
archaeological sites (38 prehistoric and 1 historic). Two previously recorded sites, CA-IMP4833
and CA-IMP-4829, were identified as being located within or adjacent to the project corridor.
CA-IMP-4833 is described as a historic cairn and trail segment located near the eastern end of
the road. CA-IMP-4829 is described as a prehistoric quartz chipping station in the same
vicinity. In addition, one isolated feature (13-009617), which consists of International Boundary
Monument No. 225, was also identified adjacent to the project corridor.
GSRC Archaeologists David Hart, Dean Barnes, and Adam Searcy conducted the Class III
intensive survey of the entire project area under California BLM Permit No. CA-12-09;
Fieldwork Authorization No. CA-670-12-086-FA-01 from July 9 through July 11, 2012. GSRC
has submitted a Draft Cultural Resources Survey Report to the BLM El Centro Field Office for
review and approval. Mr. John Bathke, Tribe Historic Preservation Officer of the Fort Yuma
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Quechan Tribe was on-site while GSRC conducted the survey. No new archaeological sites and
nine isolated occurrences (IOs) were identified and recorded. The IOs consist of five General
Land Office (GLO) historic survey markers, a scatter of milled lumber and nails, International
Boundary Monument No. 224, a tobacco tin, and a shell fragment.
GSRC attempted to relocate both of the previously recorded archaeological sites, CA-IMP-4829
and CA-IMP-4833, as part of the pedestrian survey. GSRC determined that both sites have been
completely destroyed by an extensive gravel quarry operated by the Imperial Irrigation District.
There were no aboveground historic structures within a 1-mile radius of the APE.
3.11.1.2 Tribal Concerns
Section 106 of the National Historic Preservation Act requires Federal agencies to take into
account the effects of their undertakings on historic properties and defines procedures governing
Federal agencies’ statutory responsibilities. Revisions to these procedures emphasized
consultation with Native American tribes as part of the Section 106 process for all Federal
undertakings subject to Section 106 review, regardless of whether or not the undertaking is on
tribal land. GSRC requested a Sacred Lands File and Native American Contacts List Requests
on behalf of CBP on June 14, 2012, from the Native American Heritage Commission (NAHC).
On June 18, 2012, the NAHC conducted a Sacred Lands File search of its inventory and did not
identify any Native American cultural resources in the APE (Appendix A). However, the project
is proximate to Native American cultural resources (NAHC 2012).
3.11.2 Environmental Consequences
3.11.2.1 No Action Alternative
No new impacts on cultural resources would occur upon implementation of the No Action
Alternative, as no improvement or construction activities would take place. No changes in
ongoing operations would occur with this alternative.
3.11.2.2 Proposed Action Alternative
Two NRHP-eligible historic objects, International Boundary Monuments No. 224 and No. 225,
were identified through the records search and fieldwork. Both monuments would be avoided
during construction; therefore, no impacts would occur to the monuments. In the absence of any
other intact NRHP-eligible archaeological sites or historic properties located within the project
corridor, no adverse impacts are expected to occur on any cultural resources or historic
properties as a result of the Proposed Action Alternative. The California SHPO has concurred
with CBP’s determination of no adverse impacts (Appendix A). Additionally, BMPs as
described in Section 5.7 would be implemented in an effort to avoid or minimize impacts on the
GLO markers.
3.11.2.3 BP Hill Improvement Alternative
The impacts under the BP Hill Improvement Alternative are expected to be the same as those
outlined under the Proposed Action Alternative.

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3.12

ROADWAYS AND TRAFFIC

3.12.1 Affected Environment
The only paved road that has regular vehicle traffic near the project corridor is SR 98, which is
approximately 2 miles north of the project corridor. SR 98 would be used to access the project
corridor from the west and east via existing unimproved roads. Vehicles expected to travel SR
98 during construction activities include transport vehicles and delivery trucks.
3.12.2 Environmental Consequences
3.12.2.1 No Action Alternative
The No Action Alternative would not increase the use of roadways, and traffic volumes would
not change because no construction or improvements would occur.
3.12.2.2 Proposed Action Alternative
Vehicle traffic along SR 98 would be increased by approximately 40 vehicles per day during the
construction period. This increase in daily traffic volume would consist of heavy-duty delivery
trucks and construction personnel passenger vehicles. During project construction, the delivery
of materials and equipment could cause minor delays along the affected segment of SR 98.
The 2011 annual average daily traffic volume on SR 98 (Imperial Highway portion) was
approximately 1,650 vehicles per day (Caltrans 2012). The potential increase (2 percent) of
traffic associated with this alternative is well below the capacity of SR 98. Although additional
construction traffic would impair traffic flow on SR 98, these impacts would be temporary and,
therefore, minimal.
3.12.2.3 BP Hill Improvement Alternative
Under this alternative, the impacts on roadways and traffic within the project area would be
similar to those described for Proposed Action Alternative.
3.13

AESTHETICS AND VISUAL RESOURCES

3.13.1 Affected Environment
Aesthetic resources consist of the natural and man-made landscape features that appear
indigenous to the area and give a particular environment its visual characteristics. Construction
would occur in the Yuha Basin ACEC on Federal lands managed by the BLM. BLM manages
these lands to ensure that activities preserve the character of the landscape. Lands controlled by
BLM are assigned a visual resource inventory class, which has a two-fold purpose. First, it
serves as an inventory tool that portrays the relative value of the visual resources, and secondly,
it serves as a management tool that portrays the visual management objectives.
Visual resources are divided into four Visual Resource Management (VRM) classes. The project
area and its vicinity are characterized as VRM Class III. The objective of VRM Class III is to
partially retain the existing character of the landscape. Management activities can attract
attention but should not dominate the view of the public. The level of change to the
characteristic landscape can be moderate to high.

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The project corridor has limited aesthetic value due to past and ongoing human activities within
and adjacent to the project corridor. The project corridor is adjacent to CBP infrastructure (i.e.,
vehicle barriers), IID gravel/sand quarry, and a water treatment facility and associated roads in
Mexico. In addition, the project corridor has been degraded due to illegal foot and vehicle traffic
and subsequent law enforcement actions.
3.13.2 Environmental Consequences
3.13.2.1 No Action Alternative
Aesthetics in the project corridor would continue to diminish with the implementation of the No
Action Alternative. The vegetation and landscape within the area would continue to be
destroyed and trampled. Thus, negative impacts on aesthetics and visual resources in the area
would be expected to continue with the selection of the No Action Alternative.
3.13.2.2 Proposed Action Alternative
Degradation of the aesthetic value of the project area would occur during construction, within the
immediate area. It should be noted, however, that the proposed site is adjacent to the
U.S./Mexico border, which has been heavily degraded due to illegal vehicle/foot traffic and the
subsequent USBP actions required to monitor and halt/apprehend these illegal activities. A
minor to negligible visual impact would occur initially after construction activities but would be
reduced over time. The varied and undulating terrain along the project corridor would preclude
sight of the proposed construction and improvement activities, except in the immediate vicinity
and/or from high vantage points. The Proposed Action Alternative is consistent with the visual
resource management goals of the BLM. Thus, no major impacts on aesthetics and visual
resources within the project corridor are expected.
3.13.2.3 BP Hill Improvement Alternative
Under this alternative, the impacts on aesthetics and visual resources within the area would be
the same as those described for the Proposed Action Alternative.
3.14

HAZARDOUS MATERIALS

3.14.1 Affected Environment
There are a total of 10 Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) Superfund sites identified within Imperial County; however, none are located on
or near the proposed project corridor (USEPA 2012). Only one site, located north of the City of
Calexico and approximately 15 miles from the proposed site location, is designated as a
Superfund site and is currently listed as having National Priorities List (NPL) status. In addition,
no Resource Conservation and Recovery Act (RCRA) violation and corrective action sites,
Leaking Underground Storage Tanks sites, NPL sites, or No Further Remedial Action Planned
sites are known to exist near the proposed project corridor (USEPA 2012c).
No visual evidence of hazardous materials or environmental liabilities, including odors, drums,
stained soil, stressed vegetation, wastewater, wells, and/or septic tanks, were observed during the
site visit on June 28, 2012. According to USEPA (2012c), there is no known or suspected toxic
and/or hazardous material contamination in the area surrounding the proposed project corridor,
and there are no known historic land uses at the proposed sites that might have resulted in toxic
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or hazardous material contamination of the underlying soil and/or groundwater resources. A
transaction screen assessment, in accordance with American Society for Testing and Materials
(ASTM) standard E1528-06 was performed for the project corridor, and no potential
environmental concerns were identified.
3.14.2 Environmental Consequences
3.14.2.1 No Action Alternative
No impacts would occur on hazardous materials or wastes upon implementation of the No
Action Alternative.
3.14.2.2 Proposed Action Alternative
No hazardous materials were observed during field surveys. In addition, no known state or
Federal sites with known contamination exists in the project corridor area. Temporary impacts
could occur, as the potential exists that POL and other hazardous materials could be released
during improvement and construction activities. Through the use of proper BMPs (see Section
5), frequent vehicle inspections, and careful handling of hazardous materials, the possibility of
either leaks or spills would be minimized; thus, no or negligible impacts are expected to occur.
3.14.2.3 BP Hill Improvement Alternative
Under the BP Hill Improvement Alternative, the impacts from hazardous wastes and materials
within the project area would be the same as those described for the Proposed Action
Alternative.
3.15

SOCIOECONOMICS

3.15.1 Affected Environment
This socioeconomics section outlines the basic attributes of population and economic activity in
Imperial County, California, and the City of Calexico. The area is sparsely populated and
relatively low-income, and in 2011, Imperial County had the highest unemployment rate of any
county in the Nation, with an annual average unemployment rate of 29.7 percent.
3.15.1.1 Population
Population data for Imperial County, Calexico, and the study area census tract are shown in
Table 3-7. Imperial County and Calexico grew rapidly, 22.6 and 42.3 percent, respectively, over
the last decade, while California’s population growth (10 percent) was in line with growth across
the Nation (9.7 percent).
Table 3-7. Population
Census Tract 123.01
2010 Population
2000 Population
Percent Change

5,633
5,202
8.3

Calexico
38,572
27,109
42.3

Imperial County
174,528
142,361
22.6

California
37,253,956
33,871,648
10.0

Source: U.S. Census Bureau 2000 and 2010a.

The project area is a high minority area, as shown in Table 3-8. According to the 2010 Census,
more than 80 percent of the population of Imperial County and more than 96 percent of
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Calexico’s population reports being of Hispanic or Latino origin. Slightly more than half of the
population of Census Tract 123.01 reports being of Hispanic or Latino origin, with the census
tract also reporting almost 28 percent Black or African American.
Table 3-8. Race and Ethnicity
Hispanic
Imperial County
Calexico
Census Tract 123.01
California
United States

White, Not
Hispanic

80.4
96.8
51.1
37.6
16.3

Black or African
American

13.7
1.7
19.3
40.1
63.7

3.8
0.6
27.8
7.2
13.6

Source: U.S. Census Bureau 2010a.

As shown in Table 3-9, American Community Survey estimates show that Imperial County has a
much lower percentage of high school and college graduates than the State of California and the
Nation. In Imperial County, only 62.3 percent of persons age 25 and above have a high school
credential compared to more than 80 percent for the State of California and 85 percent for the
Nation. Only about 12 percent of Imperial County residents have a bachelor’s degree or higher
compared to more than 30 percent for California and almost 28 percent for the Nation.
Table 3-9. Educational Attainment
Percent of Persons Age 25+
High school graduate
Bachelor's degree or higher

United
Imperial
California
States
County
62.3%
12.2%

80.7%
30.1%

85.0%
27.9%

Source: U.S. Census Bureau 2010b

3.15.1.2 Employment, Poverty Levels, and Income
In 2011, the annual average labor force in Imperial County was 77,561. The unemployment rate
was 29.7 percent, the highest county unemployment rate in the Nation. It was more than triple
the National unemployment rate of 8.9 percent and well above the 11.7 percent unemployment
rate for the State of California (U.S. Bureau of Labor Statistics 2011).
The economy of the region is heavily based on agriculture, with farms irrigated using water from
the Colorado River via the All-American Canal. The county is an important producer of
vegetable and melon crops, field crops, and livestock, with top commodities including cattle,
lettuce, and alfalfa (Imperial County 2010).
County Business Patterns data show that employment in Imperial County is concentrated in the
“retail,” “healthcare and social assistance,” and “accommodation and food services” categories,
as shown in Table 3-10. Together they account for approximately 51 percent of employment in
Imperial County, compared to 35 percent for California and 38 percent for the U.S. The “retail”
and “accommodation and food services” industries are historically lower-paying industries.
Industries that are typically higher-paying, such as “information” and “professional, scientific,

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and technical services,” account for only about 4 percent of employment in Imperial County
compared to 13 percent for the State of California.
Table 3-10. Employment by Industry Sector (Percent of Total)
Imperial
County

California

2%
<1%
NA
5%
11%
6%
25%
5%
1%
3%
2%
3%
<1%

<1%
<1%
NA
5%
10%
6%
12%
3%
4%
5%
2%
9%
2%

<1%
1%
1%
5%
10%
5%
13%
4%
3%
5%
2%
7%
2%

5%

8%

8%

1%
14%
2%
12%
3%
<1%

3%
13%
<1%
10%
4%
<1%

3%
15%
2%
10%
5%
NA

Forestry, fishing, hunting, and agricultural support
Mining, quarrying, and oil and gas extraction
Utilities
Construction
Manufacturing
Wholesale trade
Retail trade
Transportation and warehousing
Information
Finance and insurance
Real estate and rental and leasing
Professional, scientific, and technical services
Management of companies and enterprises
Admin & Support; Waste Management & Remediation
Services
Educational services
Health care and social assistance
Arts, entertainment, and recreation
Accommodation and food services
Other services (except public administration)
Industries not classified

United
States

Source: U.S. Census Bureau 2009

Income and poverty data are shown in Table 3-11. Per capita income for Imperial County is very
low at $27,342, which is 68.5 percent of the National average. Per capita income for California,
$42,514, is more than 106 percent of the National average. Median household income for
Imperial County and Calexico are also well below California and the Nation (U.S. Bureau of
Economic Analysis [BEA], 2009).
Table 3-11. Income and Poverty
Census
Tract
123.01
Per capita personal income (dollars), 2009
Per capita income as a percent of U.S., 2009
Median Household Income (2006-2010)
Persons of all ages below poverty level,
percent, 2006-2010

Calexico

Imperial
California
County

United
States

NA
NA
$34,848
19.5

$27,342
68.5
$38,685

$42,514
106.5
$60,883

$39,937
100
$51,914

22.1

21.4

13.7

13.8

Sources: U.S. Census Bureau 2010b and U.S. BEA 2009.

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As might be expected based on the income numbers and unemployment rate, the poverty rates
for Imperial County and the City of Calexico (21.4 and 22.1 percent, respectively) are well above
the poverty rates for California (13.7 percent) and the Nation (13.8 percent) (U.S. Census Bureau
2010b).
3.15.1.3 Housing
Data on housing units in the project area, California, and the Nation are presented in Table 3-12.
These data show that in Census Tract 123.01, a much higher than average percentage of the
population lives in the homes they own, with 74 percent of the homes owner-occupied, compared
to about 55 percent for Imperial County and 65 percent for the Nation. The homeowner and
rental vacancy rates in Census Tract 123.01 are also much higher than the county, the state, and
the Nation.
Table 3-12. Housing Units
Geographic
Area
Census Tract
123.01
Calexico
Imperial
County
State of
California
United States

Total
Housing
Units

Occupied

Units

Percent
Owner
Occupied

Percent
Renter
Occupied

Homeowner
Vacancy
Rate*
(Percent)

Rental
Vacancy
Rate**
(Percent)

Vacant
Units for
Rent

975

448

74.0

26.0

7.1

16.1

151

10,651

10,116

53.7

46.3

2.6

3.1

23

56,067

49,126

55.9

44.1

3.5

7.5

1,762

13,680,081

12,577,498

55.9

44.1

2.1

6.3

374,610

131,704,730

116,716,292

65.1

34.9

2.4

9.2

4,137,567

Source: U.S. Census Bureau 2010a
*Homeowner vacancy rate is the proportion of the homeowner inventory that is vacant "for sale."
** Rental vacancy rate is the proportion of the rental inventory that is vacant "for rent."

3.15.2 Environmental Consequences
3.15.2.1 No Action Alternative
The No Action Alternative would result in no new impacts on socioeconomics within the region,
as no road construction and improvements would occur.
3.15.2.2 Proposed Action Alternative
The proposed project area is located approximately 10 miles west of the nearest populated area,
Calexico, California. During construction there would be a temporary but minimal increase in
population from the addition of construction crews in the area. No housing units or businesses
are located within the footprint of the Proposed Action Alternative, so no displacement of
existing people or businesses would be anticipated. Construction crews would stay at hotels. As
a result, no additional demand for housing is anticipated during construction. No major adverse
impacts on the regional economy or demographics would be anticipated from the Proposed
Action Alternative. However, the proposed improvements would have temporary cumulative
beneficial impacts on the region’s economy due to temporary employment and sales taxes
generated through the purchase of construction-related items such as fuel and food.

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3.15.2.3 BP Hill Improvement Alternative
Under the BP Hill Improvement Alternative, the impacts on regional economy or demographics
would be the same as those described for the Proposed Action Alternative.
3.16

HUMAN HEALTH AND SAFETY

3.16.1 Affected Environment
Human health effects occur in a variety of forms, such as exposure to chemicals, extreme
temperatures, weather, and physical security and safety. Generally, human health factors are
driven by factors that differ substantially by geographic area. In the project area, factors that
could impact human health range from automobile accidents, extreme weather such as wildfires
and high temperatures, and physical security on the site, as well as minimizing the chance that
non-site workers could venture on the project site and be harmed. However, the general area
surrounding the project site consists of BLM desert scrubland. No residences or community
parks are located within 2.0 miles of the project corridor.
3.16.2 Environmental Consequences
3.16.2.1 No Action Alternative
Under the No Action Alternative, no construction would occur; therefore, there would be no
direct impacts, either beneficial or adverse, on human health and safety due to construction
activities. However, USBP agents would continue to face safety related issues while trying to
maintain and access the BP Hill RVSS tower, as well as patrol the existing border road.
3.16.2.2 Proposed Action Alternative
There is little potential for USBP agents, private contractors, BLM personnel, or the general
public to be at risk from a human health and safety aspect as a result of the Proposed Action
Alternative. Construction would occur during daylight hours, whenever possible. Safety buffer
zones would be designated around all construction sites to ensure public health and safety.
Automobile traffic associated with construction and operation of the improved roadway is not
anticipated to increase the risks of automobile accidents or roadway capacities. Through BMPs
developed for general construction practices (see Section 5.0), and because of the rural nature of
the project area with no residences located near the project footprint, negligible impacts would
be expected.
3.16.2.3 BP Hill Improvement Alternative
Under the BP Hill Improvement Alternative, the impacts on human health and safety would be
the same as those described for the Proposed Action Alternative.
3.17

SUSTAINABILITY AND GREENING

3.17.1 Affected Environment
In accordance with EO 13423, Strengthening Federal Environmental, Energy, and Transportation
Management (72 FR 3919), CBP would incorporate practices in an environmentally,
economically, and fiscally sound, integrated, continuously improving, efficient, and sustainable
manner in support of its mission. CBP implements practices throughout the agency to:
1) improve energy efficiency and reduce GHG emissions; 2) implement renewable energy
projects; 3) reduce water consumption; 4) incorporate sustainable environmental practices such
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as recycling and the purchase of recycled-content products; and 5) reduce the quantity of toxic
and hazardous materials used and disposed of by the agency.
3.17.2 Environmental Consequences
3.17.2.1 No Action Alternative
The No Action Alternative would not increase the use of fossil fuels or GHG emissions because
no additional construction would occur.
3.17.2.2 Proposed Action Alternative
Under the Proposed Action Alternative, the Federal sustainability and greening practices would
be implemented, to the maximum extent practicable. No major impacts regarding Sustainability
and Greening would occur.
3.17.2.3 BP Hill Improvement Alternative
Under the BP Hill Improvement Alternative, the impacts on sustainability and greening would be
the same as those described for the Proposed Action Alternative.
3.18

PALEONTOLOGICAL RESOURCES

3.18.1 Affected Environment
The surface and near-surface geologic units in the project area are of Recent and Holocene age,
between 500 and 8,000 years old, and are a result of deposition of sediments in and around the
ancient Lake Cahuilla (San Diego State University 2012). Lake Cahuilla was the predecessor of
the current Salton Sea, and held a significant volume of fresh to slightly brackish water. Studies
of the history of Lake Cahuilla indicate that the lake was active from the Pleistocene glacial
periods to as recent as 500 years B.P. Sediments deposited in the lake and on shorelines around
the lake contain dead vertebrate (fish) and invertebrate (gastropods and mollusks) organisms, but
the types of organisms present in Lake Cahuilla are nearly identical to those presently found in
the Salton Sea remnant of the ancient lake. Also, during the active period of Lake Cahuilla,
Native American peoples lived around the shores of the lake and harvested organisms for food
(Salton Sea Authority 2012). Discarded shells and fish bones would have been reworked by
humans and thus would be considered archaeological artifacts, not fossils. The Proposed Action
would occur near the center of the former Lake Cahuilla, and sediments in that area would be the
youngest due to the retreat of the lake toward the center as water evaporated through time.
Therefore, the potential for discovery of significant paleontological resources during any
excavation activities is considered low.
3.18.2 Environmental Consequences
3.18.2.1 No Action Alternative
The No Action Alternative would result in no new impacts on paleontological resources within
the region, as no road construction or improvements would occur.
3.18.2.2 Proposed Action Alternative
A pedestrian archaeological survey of the project corridor was conducted, and no fossil shells or
bones were identified on the surface. No relict shoreline features are present within the project
corridor, and significant recently deposited gravel and boulder material is present on the surface.
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Any fossilized shells found in these deposits would be loose, and would have no provenance
relationship with the original sediments from which they came. Additionally, based on the
geotechnical borings and cores recovered for the Proposed Action, no indurated rock strata were
recovered (Michael Baker 2012).
Using the BLM Potential Fossil Yield Classification (PFYC) System, the potential for discovery
of vertebrate fossils or scientifically significant non-vertebrate fossils would be low, fitting into
the PFYC Class 2. The deposits are younger than 10,000 years B.P., any remains found would
be identical to currently living organisms, any fossils found would be loose with no indication of
provenance, no scientific knowledge could be gained from the study of any loose fossils found,
and any concentration of shells or fish bones found would be treated as an archaeological site.
As stated in the BLM’s Instruction Memorandum Number 2008-009, the assessment or
mitigation of paleontological resources in areas classified as Class 2 is not likely to be necessary.
CBP would have cultural resources monitors on-site during ground-disturbing activities, which
will also reduce the likelihood of impacting unknown paleontological resources. Therefore, CBP
considers any potential impacts on this resource from ground-disturbing activities of the
Proposed Action to be negligible.

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SECTION 4.0
CUMULATIVE IMPACTS

00003809

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4.0

CUMULATIVE IMPACTS

NEPA regulations define cumulative impacts as an “impact on the environment which results
from the incremental impact of the action when added to other past, present, and reasonably
foreseeable future actions regardless of what agency (Federal or non-Federal) or person
undertakes such other actions” (40 CFR 1508.7). Cumulative impacts can result from
individually minor, but collectively significant, actions taking place over a period of time by
various agencies (Federal, state, and local) or individuals. Informed decision making is served
by consideration of cumulative impacts resulting from activities that are proposed, under
construction, recently completed, or anticipated to be implemented in the reasonably foreseeable
future.
This cumulative impacts analysis summarizes expected environmental effects from the combined
impacts of past, current, and reasonably foreseeable future activities that affected any part of the
human or biological environment impacted by the Proposed Action. Activities were identified
for this analysis by reviewing CBP and BLM documents, news/press releases and published
media reports, and through consultation with planning and engineering departments of local
governments, and state and Federal agencies.
4.1

CBP PROJECTS

USBP has been conducting law enforcement actions along the U.S/Mexico border since its
inception in 1924, and has continually transformed its methods as new missions, CBV modes of
operations, agent needs, and National enforcement strategies have evolved. Development and
maintenance of training ranges, station and sector facilities, detention facilities, and roads and
fences have affected hundreds of acres of resources in southern California, including the climate
and landscapes that support native plants and animals, as well as socioeconomic conditions in
border communities.
All CBP actions have been in support of the agency’s mission to gain and maintain control of the
United States’ borders. Infrastructure projects have supported the operational methods
determined to be the most effective approach to achieving the agency’s mission. Each of these
projects has been compliant with NEPA, and measures to avoid, minimize, or mitigate for the
adverse effects on the human and biological environment have been developed and implemented
on a project-specific basis. With continued funding and implementation of BMPs developed as
part of past, ongoing, and future actions, including environmental education and training of its
agents, use of biological and archaeological monitors, and restoration activities, the direct
impacts of these projects have been and would be prevented or minimized.
As mentioned previously, CBP published the May 2008 Environmental Stewardship Plan (ESP)
for the Construction, Operation, and Maintenance of Tactical Infrastructure, U.S. Border Patrol
(USBP), El Centro Sector, California, which described the proposed TI and any potential
environmental impacts. The TI to be constructed within the El Centro Sector was divided into
five segments designated as BV-1, B-2, B-4, B5-A, and B-5B. Segments BV-1 and B-2 adjoin
the current project area from the west and east, respectively. Within these segments, 71.8 acres

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were impacted from the construction of fence, access and patrol roads, and staging areas. The
total project footprint for all TI constructed as part of the El Centro project was 326 acres.
The Proposed Action Alternative addressed in this EA is part of a larger TI project, portions of
which are waived from NEPA and other Federal regulatory compliance by the Secretary of
DHS. The other elements of the larger TI project include the improvement, operation, and
maintenance of two staging areas, two access roads, and border road to the east and west of the
proposed project area. In addition to the Proposed Action Alternative and other elements that are
covered by the Secretary’s waiver and are part of the larger TI project, CBP has proposed and is
evaluating a program of ongoing maintenance and repair of existing tactical infrastructure within
the ROI. CBP has considered both the Proposed Action Alternative and the other elements in
examining cumulative impacts
4.2

PRIVATE/OTHER AGENCY/ORGANIZATION PROJECTS

Numerous private renewable energy projects have been identified as either ongoing or proposed
near the project area that could have a cumulative impact when combined with the Proposed
Action Alternative (BLM 2012b). These activities are described below.
Calexico Solar Farm I, Under Construction: Solar photovoltaic project encompassing
1,013 acres of farmland along the All-American Canal, west of Calexico, California.
Calexico Solar Farm II, Ongoing: Solar photovoltaic project encompassing 1,477 acres
of farmland near the All-American Canal, west of Calexico, California.
Mount Signal Solar Farm, Ongoing: A proposed 200-megawatt (MW), 1,375-acre
solar project with a biomass generation component and 230-kilovolt transmission line.
This project would be located on existing farmlands.
Imperial Solar Energy Center South Solar Farm, Ongoing: This project is a
proposed 200 MW solar facility with a transmission line and associated road widening on
946.6 acres of existing farmlands, which is located west of Calexico near the AllAmerican Canal.
Centinela Solar Farm, Ongoing: This proposed solar farm consists of 2,067 acres. The
solar farm would be located on existing farmland located near SR 98, west of Calexico.
Acorn Greenworks Solar Farm, Ongoing: This project would be located north of SR
98 on approximately 693 acres and would consist of a 150 MW solar energy facility.
Silverleaf Solar Farm, Ongoing: The Silverleaf Solar Farm is proposed north of SR 98
and south of Interstate 8 near the western boundary of the YDMA in existing farmland.
The project would encompass 1,096 acres and would be a 160 MW solar photovoltaic
energy facility.
Campo Verde Solar Farm, Ongoing: Over 2,260 acres of farmland would be
converted to a 226 MW solar energy facility.
Imperial Valley Solar West Solar Farm, Ongoing: This project entails a 1,130-acre,
250 MW solar energy facility, and associated transmission line.
Sunrise Powerlink-Transmission, Project Complete: This project consists of the
construction of a 117-mile transmission line from San Diego County to the Imperial
Valley Substation. The total acreage impacted as a result of the project is approximately
282.3 acres.
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Although the renewable energy projects described above are primarily located on private lands, a
few of the projects do have components that traverse BLM lands. In general, only a transmission
line needs to be constructed across BLM lands with minimal disturbance being created. BLM is
also in the process of potentially approving a renewable energy project wholly within BLM lands
(i.e., Ocotillo Solar Project). The Ocotillo Solar Project would impact approximately 102 acres
of locally and regionally common creosote-white bursage vegetative community. No major
adverse impacts on Federally protected species, Waters of the U.S., or cultural resources are
expected as a result of the project.
4.3

IDENTIFICATION OF CUMULATIVE EFFECTS ISSUES

Impacts on each resource can vary in degree or magnitude from a slightly noticeable change to a
total change in the environment. For the purpose of this analysis, the intensity of impacts will be
classified as negligible, minor, moderate, or major. These intensity thresholds were previously
defined in Section 3.1.
4.3.1 Land Use
A major impact would occur if any action is inconsistent with adopted land use plans or if an
action would substantially alter those resources required for supporting or benefiting the current
use. Improvements and construction of the roads would change land use from recreation to CBP
infrastructure. This change would be minor because it would be located near the heavily
disturbed U.S./Mexico border (which is typically not used for recreation) and within an existing
road. CBV activities and CBP and law enforcement activities have historically and recently
cumulatively impacted land uses for public lands in Southern California. Although land use in
Southern California has changed dramatically over time, in recent history, management of the
lands affected by the Proposed Action Alternative has been consistent with the mission of BLM.
Additionally, the combination of the Proposed Action Alternative and other planned projects
within the YDMA would not exceed the one percent cap of cumulative impacts as allowed per
the FTHL Rangewide Management Strategy. Therefore, when the Proposed Action Alternative
is combined with other projects in the area, it would have a negligible cumulative effect on the
ability of land managers to implement land use policies.
4.3.2 Soils
A major impact would occur if the action exacerbates or promotes long-term erosion, if the soils
are inappropriate for the proposed construction and would create a risk to life or property, or if
there would be a substantial reduction in agricultural production or loss of prime farmland soils.
Within the project area, it is estimated that the CBP would remove up to 7.5 acres of primarily
disturbed soils from production. Other CBP projects, such as the pedestrian and vehicle fence
projects in southern Imperial County, have resulted in hundreds of acres of soils disturbance;
however, these soils were regionally and locally common. Although the road improvements and
construction would impact negligible amounts of soils, the cumulative impacts on soils from
CBP projects, private entity projects, and land management activities from other agencies, such
as BLM, would not be considered a major cumulative adverse impact.

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4.3.3 Geology
The Proposed Action Alternative would not affect geologic resources. Therefore, this action,
when combined with other existing and proposed projects in the region, would result in a
negligible cumulative impact on geologic resources.
4.3.4 Vegetation
The significance threshold for vegetation would include a substantial reduction in ecological
processes, communities, or populations that would threaten the long-term viability of a species or
result in the substantial loss of a sensitive community that could not be offset or otherwise
compensated. The proposed project would permanently impact up to 7.5 acres that is sparsely
vegetated (less than five percent ground cover). The other CBP projects in the region were also
located in degraded, sparsely vegetated areas (Algododunes Dunes and All-American Canal).
The solar farms planned in the region would be constructed primarily on existing agricultural
lands. Therefore, when the Proposed Action Alternative is combined with other private and
BLM projects in the region, negligible cumulative impacts on native vegetation communities
would occur.
4.3.5 Wildlife
The significance threshold for wildlife and aquatic resources would include a substantial
reduction in ecological processes, communities, or populations that would threaten the long-term
viability of a species or result in the substantial loss of a sensitive community that could not be
offset or otherwise compensated. Past CBP projects were completed within areas that were
degraded from past activities and within areas of sparse vegetation. As mentioned previously,
the other ongoing or proposed projects in the region are primarily located within existing
agricultural areas. Most of the land use in the region is undeveloped and would be unchanged,
even with the Proposed Action Alternative and other development projects. Therefore, this
proposed project, in conjunction with other regionally proposed projects, would have a negligible
impact on regional wildlife populations due to loss of habitat.
4.3.6 Protected Species and Critical Habitats
A major impact on threatened and endangered species would occur if any action resulted in a
jeopardy opinion for any endangered, threatened, or rare species. No adverse cumulative
impacts would occur, as the Proposed Action Alternative would have no effects on any
Federally-listed or state-listed threatened or endangered species. Conversely, the Proposed
Action Alternative would have an adverse effect on one conservation species, FTHL, due to
habitat loss and potential individual mortality. Although up to 7.5 acres of habitat would be
permanently impacted, only 3.6 of those acres are considered undisturbed. CBP has agreed to
implement mitigation measures (minimize impacts, provide biological monitors, and provide
compensation) that would offset any impacts to achieve no adverse impacts on the FTHL or its
habitat. This project when combined with other ground–disturbing or development projects in
the region, would have minor cumulative impacts on FTHL.
4.3.7 Water Resources
The construction, improvement, and maintenance of proposed roadways would have no impact
on groundwater or wetlands and less than 0.2 acre of surface waters (ephemeral washes) would
be impacted. The implementation of BMPs would reduce erosion and sedimentation during
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construction to negligible levels and would eliminate post-construction erosion and
sedimentation from the project area. The same measures would be implemented for other
construction projects; therefore, cumulative impacts would be considered negligible.
4.3.8 Air Quality
Numerous activities have affected air quality throughout the region. As part of compliance with
the Federal General Conformity Rule, GSRC performed an air conformity analysis during the
development of this EA. It was determined that the impacts of the Proposed Action Alternative
would be temporary, minor, and below the de minimis threshold presented in the General
Conformity Rule. Other projects in the airshed do not exceed de minimis thresholds and the
combination of these projects should not cause an exceedance of Federal ambient air quality
standards. Thus, the Proposed Action Alternative in combination with other projects would
have a negligible adverse cumulative effect on air quality. Long-term beneficial impacts from
the reduction of fugitive dust would occur as the solar farms are constructed within old
agricultural fields.
4.3.9 Noise
Actions would be considered to cause major impacts if they permanently increase ambient noise
levels over 65 dBA. Most of the noise generated by the Proposed Action Alternative would
occur during construction and, thus, would not contribute to cumulative impacts on ambient
noise levels. Maintenance activities along the roads would create a minor increase in ambient
noise levels; however, potential sources of noise from periodic maintenance operations are not
sufficient (temporal or spatial) to increase day-night average ambient noise levels above the 50
dBA range at the proposed site. The other projects occurring or potentially occurring within the
ROI are removed from the proposed project area and construction activities would likely not be
contemporaneous. Therefore, the potential for cumulative impacts is negligible.
4.3.10 Cultural Resources
The Proposed Action Alternative would not affect cultural resources or historic properties.
Therefore, this action, when combined with other existing and proposed projects in the region,
would result in a negligible cumulative impact on cultural resources or historic properties.
4.3.11 Aesthetics and Visual Resources
Actions that cause the permanent loss of the characteristics that make an area visually unique or
sensitive would be considered to cause a major impact. No major impacts on visual resources
would occur from implementing the Proposed Action Alternative, due in part to the site being
previously disturbed, adjacent to existing CBP infrastructure, a gravel/sand quarry, and other
development in Mexico. This project, in conjunction with other projects in the region, would not
result in major adverse cumulative impacts on the region’s visual resources.
4.3.12 Hazardous Materials
The Proposed Action includes measures to reduce the potential effects of pollutants associated
with the handling of POL, VOC, and hazardous materials, and would have a minor cumulative
effect on hazardous waste.

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4.3.13 Socioeconomic
Construction of the proposed improvements would have temporary cumulative beneficial
impacts on the region’s economy due to temporary employment and sales taxes generated
through the purchase of construction-related items such as fuel and food. When combined with
the other currently proposed or ongoing projects within the region, the Proposed Action
Alternative is considered to have minor beneficial cumulative impacts.
4.3.14 Human Health and Safety
No health or safety risks would be created by the Proposed Action Alternative. In fact, the
improvements are intended to reduce safety risks to USBP agents and the public, especially
when agents are able to be more effective in reaching currently less accessible areas. When
combined with other ongoing and proposed projects in the region, the Proposed Action
Alternative would have a negligible cumulative effect.

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00003816

SECTION 5.0
BEST MANAGEMENT PRACTICES

00003817

00003818
5-1

5.0

BEST MANAGEMENT PRACTICES

It is CBP’s policy to reduce impacts through a sequence of avoidance, minimization, mitigation,
and compensation. This chapter describes those measures that would be implemented to reduce
or eliminate potential adverse impacts on the human and natural environment. Many of these
measures have been incorporated as standard operating procedures by CBP on past projects.
BMPs are presented for each resource category potentially affected.
5.1

PROJECT PLANNING/DESIGN – GENERAL CONSTRUCTION

The all-weather road will be sited, designed, and improved/constructed to avoid or minimize
habitat loss within or adjacent to the footprint. The amount of aboveground obstacles associated
with the site will be minimized.
CBP will ensure that all construction will follow DHS Directive 025-01 for Sustainable Practices
for Environmental, Energy, and Transportation Management.
CBP will incorporate BMPs relating to project area delineation, water sources, waste
management, and site restoration into project planning and implementation for construction and
maintenance.
5.2

GENERAL CONSTRUCTION ACTIVITIES

CBP will clearly demarcate project construction area perimeters with a representative from the
land management agency. No disturbance outside that perimeter will be authorized without prior
coordination and approval of the land manager.
Within the designated disturbance area, CBP will minimize the area to be disturbed by limiting
deliveries of materials and equipment to only those needed for effective project implementation.
CBP will avoid contamination of ground and surface waters by storing any water that has been
contaminated with construction materials, oils, equipment residue, etc., in closed containers onsite until removed for disposal. This wash water is toxic to wildlife. Storage tanks must have
proper air space (to avoid rainfall-induced overtopping), be on-ground containers, and be located
in upland areas instead of washes.
In the event that CBP contaminates soil or water resources as a result of the proposed project, the
contaminated soil or water will be remediated as per BLM requirements.
CBP will avoid transmitting disease vectors, introducing invasive non-native species, and
depleting natural aquatic systems by using wells, irrigation water sources, or treated municipal
sources for construction or irrigation purposes instead of natural sources.
CBP will place drip pans under parked equipment and establish containment zones when
refueling vehicles or equipment.

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5.3

VEGETATION

CBP will minimize habitat disturbance by restricting vegetation removal to the smallest possible
project footprint. Native seeds or plants, which are compatible with the enhancement of
protected species, will be used to the greatest extent practicable, as required under Section
7(a)(1) of the ESA, to rehabilitate staging areas and other temporarily disturbed areas.
Additionally, organic material will be collected and stockpiled during construction to be used for
erosion control after construction while the areas naturally rehabilitate.
Construction equipment will be cleaned at temporary staging areas, in accordance with BMPs,
prior to entering and departing project areas to minimize the spread and establishment of nonnative invasive plant species.
5.4

WILDLIFE RESOURCES

The Migratory Bird Treaty Act (MBTA) (16 USC 703-712, [1918, as amended 1936, 1960,
1968, 1969, 1974, 1978, 1986 and 1989]) requires that Federal agencies coordinate with the
USFWS if a construction activity would result in the take of a migratory bird. If construction or
clearing activities are scheduled during nesting season (February 15 through September 1),
surveys will be performed to identify active nests. If construction activities will result in the take
of a migratory bird, then coordination with the USFWS and CDFG will be required and
applicable permits would be obtained prior to construction or clearing activities. Another
mitigation measure that would be considered is to schedule all construction activities outside
nesting season, negating the requirement for nesting bird surveys.
CBP will not, for any length of time, permit any pets inside the project area or adjacent native
habitats. This BMP does not pertain to law enforcement animals.
5.5

PROTECTED SPECIES

Construction equipment will be cleaned prior to entering and departing the project corridor area
to minimize the spread and establishment of nonnative invasive plant species. Soil disturbances
in temporary impact areas would be rehabilitated. Designated travel corridors would be marked
with easily observed removable or biodegradable markers, and travel would be restricted to
established road construction areas.
A qualified monitor will be present during the improvement, construction, and maintenance of
the proposed roads in FTHL habitat. Duties of the monitor(s) would include surveying the
roadways prior to improvement/construction and removing and relocating lizards outside the
project area. In addition, CBP would compensate for loss of habitat using the formula outlined
in the FTHL Rangewide Management Strategy.
Based upon field visits, aerial photography, and discussions with BLM, CBP has determined that
of the potential 7.5 acres of habitat permanently impacted only 3.6 of those acres are considered
undisturbed native habitat (the new BP Hill road is included in this acreage). The remaining 3.9
acres consists of previously disturbed habitat in the form of the existing roadway (15 feet wide)
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and the extant IID gravel/sand quarry area (the eastern 2,300 feet of the project corridor).
Figure 5-1 is a schematic showing how CBP classified the disturbed versus undisturbed acreages
along the existing border road.
The Rangewide Management Strategy formula uses a multiplying factor (M) ranging from 3 to 6
to be applied to the affected acreage to obtain an adjusted compensation acreage. The formula is
as follows:
M=3+A+G+E+D
A

Adjacent habitat impacts:
a) Adjacent lands will not be affected.................................................0
b) Adjacent lands will receive direct or
indirect deleterious impacts .........................................................0.5

G

Growth-inducing effects within FTHL habitat:
a) The project will have no growth-inducing effects ..........................0
b) The project will have growth-inducing effects ............................0.5

E

Existing disturbance on-site:
a) There is moderate to heavy existing habitat disturbance ................0
b) There is little or no existing habitat disturbance.............................1

D

Duration of effect:
a) The effects of the project are expected to be short-term
(less than 10 years) .......................................................................... 0
b) The effects of the project are expected to be long-term
(greater than 10 years) ..................................................................... 1

CBP calculated M for the project areas classified as being undisturbed as, M = 3 + 0 + 0 + 1 + 1,
generating a compensation ratio of 5:1. For project areas classified as being disturbed, CBP
calculated M as, M = 3 + 0 + 0 +0 + 1. Table 5-1 provides the required compensation ratio for
impacts on FTHL habitat.
Table 5-1. Compensation for Impacts on FTHL habitat
Land Classification
Undisturbed
Disturbed

Compensation Ratio
5:1
4:1

Required
Compensation Area
(Acres)

Impact Area
(Acres)
3.6
3.9

18.0
15.6

The total compensation for impacts on FTHL habitat will be up to 33.6 acres.
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WESTERNMOST
POINT OF
PROJECT AREA
15'

40'

IID QUARRY

EXISTING BORDER ROAD

IID QUARRY

2,300'

Figure 5-1. Schematic Showing Disturbed Versus Undisturbed Areas

UNDISTURBED

EXISTING BORDER ROAD

UNDISTURBED

Disturbed Area

12.5'

12.5'

5,092'

October 2012

NOT TO SCALE

EASTERNMOST
POINT OF
PROJECT AREA

5-4
00003821

00003822
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During FTHL monitoring efforts, the on-site biologist will also survey for western burrowing
owls, kit fox, and badgers. If an individual of any of these three species are seen occupying a
burrow or structure in the project, CDFG recommended buffers will be provided until the animal
has left the project area. In the event, a western burrowing owl is observed; one-way doors on
burrows may be used to evict the owl during the non-breeding season.
5.6

WATER RESOURCES

Standard construction procedures will be implemented to minimize the potential for erosion and
sedimentation during construction. All work will cease during heavy rains and would not
resume until conditions are suitable for the movement of equipment and material. No refueling
or storage will take place within 100 feet of drainages.
CBP will avoid contaminating natural aquatic systems with runoff by limiting all equipment
maintenance, staging, laydown, and dispensing of fuel, oil, etc., to designated upland areas.
A SWPPP will be prepared. A Spill Prevention Control and Countermeasures Plan will be
maintained to ensure that all are aware of its implementation requirements in the event of a spill.
5.7

CULTURAL RESOURCES

Cultural resource monitors will be on site during all ground-disturbing activities for the Proposed
Action Alternative. Additionally, the five GLO survey markers will be flagged for avoidance
prior to improvement or construction activities.
Should any archaeological artifacts be found during staging or installation activities, the
appropriate BLM archaeologist or cultural resources specialist would be notified immediately.
All work will cease until an evaluation of the discovery is made by the authorized officer to
determine appropriate actions to prevent the loss of significant cultural or scientific values.
5.8

AIR QUALITY

In order to minimize the amount of project-related dust emissions, the contractors will comply
with Imperial County Air Pollution Control District’s requirements (Rule 800) for control of
particulate matter (PM-10). Rule 800 provides guidance for contractors that: (1) minimize land
disturbance; (2) insure saturation of exposed areas; and (3) control fugitive dust caused by
hauling activities and vehicular travel on unpaved road surfaces. In addition, all construction
equipment shall be maintained and operated in a manner that produces the least amount of
emissions. All construction equipment and vehicles and must be maintained in good operating
condition, free from leaks.
5.9

NOISE

During the construction and improvement and maintenance of the proposed roadways, short-term
noise impacts are anticipated. All applicable Occupational Safety and Health Administration
regulations and requirements will be followed. On-site activities would be restricted to daylight
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hours, to the greatest extent practicable. All equipment will possess properly working mufflers
and would be kept properly tuned to reduce backfires.
5.10

HAZARDOUS MATERIALS

BMPs will be implemented as standard operating procedures during all construction activities,
and will include proper handling, storage, and/or disposal of hazardous and/or regulated
materials. To minimize potential impacts from hazardous and regulated materials, all fuels,
waste oils, and solvents will be collected and stored in tanks or drums within a secondary
containment system that consists of an impervious floor and bermed sidewalls capable of
containing the volume of the largest container stored therein. The refueling of machinery will be
completed in accordance with accepted industry and regulatory guidelines, and all vehicles will
have drip pans during storage to contain minor spills and drips. Although it is unlikely that a
major spill would occur, any spill of reportable quantities will be contained immediately within
an earthen dike, and the application of an absorbent (e.g., granular, pillow, sock) will be used to
absorb and contain the spill.
CBP will contain non-hazardous waste materials and other discarded materials, such as
construction waste, until removed from the construction and maintenance sites. This will assist
in keeping the project area and surroundings free of litter and reduce the amount of disturbed
area needed for waste storage.
CBP will minimize site disturbance and avoid attracting predators by promptly removing waste
materials, wrappers, and debris from the site. Any waste that must remain more than 12 hours
should be properly stored until disposal.
All waste oil and solvents will be recycled. All non-recyclable hazardous and regulated wastes
will be collected, characterized, labeled, stored, transported, and disposed of in accordance with
all applicable Federal, state, and local regulations, including proper waste manifesting
procedures.
Solid waste receptacles will be maintained at the construction staging area. Non-hazardous solid
waste (trash and waste construction materials) will be collected and deposited in on-site
receptacles. Solid waste will be collected and disposed of by a local waste disposal contractor.

West Desert Road EA

Final
February 2013

00003824

SECTION 6.0
REFERENCES

00003825

00003826
6-1

6.0

REFERENCES

Alles, David L. (editor). 2011. The Lower Colorado River. Available online:
http://fire.biol.wwu.edu/trent/alles/LowerColorado.pdf.
Brown. 1994. Biotic Communities, Southwestern United States and Northwestern Mexico.
University of Utah Press. Salt Lake City. 342 pp.
Bureau of Land Management (BLM). 1999. The California Desert Conservation Area Plan
1980 as amended. Available online:
http://www.blm.gov/pgdata/etc/medialib/blm/ca/pdf/cdd/cdcaplan.Par.15259.File.dat/CA
_Desert_.pdf Accessed: May 9, 2012.
BLM. 2012b. Draft Environmental Impact Statement, Draft CDCA Plan Amendment, Ocotillo
Sol Project, Volume I of II, April 2012. Available online:
http://www.blm.gov/pgdata/etc/medialib/blm/ca/pdf/elcentro/nepa/ocotillosol.Par.49849.
File.dat/Ocotillo_Sol_DEIS_Volume1_508.pdf. Accessed: July 2012.
California Air Resources Board (CARB). 2012. Air Quality Standards and Area Designations.
Last Accessed: 8/9/2012. http://www.arb.ca.gov/desig/desig.htm.
California Department of Conservation. 1999. Fault-Rupture Hazard Zones in California,
Division of Mines and Geology Special Publication 42, by Earl W. Hart and William A.
Bryant.
California Department of Fish and Game (CDFG). 2012. State and Federally Listed Endangered
and Threatened Animals of California. Available at:
http://www.dfg.ca.gov/biogeodata/cnddb/pdfs/TEAnimals.pdf. Last Accessed: May 8,
2012.
California Department of Public Works. 2004. California’s Groundwater, Bulletin 118, Yuma
Valley Groundwater Basin, updated February 27, 2004.
California Department of Transportation (Caltrans). 1998. Technical Noise Supplement by the
California Department of Transportation Environmental Program Environmental
Engineering-Noise, Air Quality, and Hazardous Waste Management Office. October
1998. Page 24-28.
Caltrans. 2012. Traffic and Vehicle Data Systems Unit, 2011 All Traffic Volumes on CSHS.
Internet URL: http://www.dot.ca.gov/hq/traffops/saferesr/trafdata/2011all/Route9298.html.
California Department of Water Resources (CDWR). 2004. Coyote Wells Valley Groundwater
Basin.

West Desert Road EA

Final
February 2013

00003827
6-2

California Energy Commission. 2007. 2007 Integrated Energy Policy Report, CEC-100-2007008-CMF.
California Geological Survey. 2002. California Geomorphic Provinces, Note 36.
California Geological Survey. 2010. 2010 Geologic Map of California.
Colorado River Basin Regional Water Quality Control Board. 2006. Water Quality Control
Plan – Colorado River Basin – Region 7. Internet URL:
http://www.swrcb.ca.gov/rwqcb7/publications_forms/publications/index.shtml. Last
Accessed: October 2010.
Council on Environmental Quality (CEQ). 2010. Memorandum for Heads of Federal
Departments and Agencies. Draft NEPA Guidance on Consideration of the Effects of
Climate Change and Greenhouse Gas Emissions. Nancy H. Sutley, February 18, 2010.
Federal Emergency Management Agency (FEMA). 2008. Imperial County, California and
Unincorporated Areas, Panel 2050 of 2300. Effective Date of Countywide Flood
Insurance Rate Map September 26, 2008.
Federal Highway Administration (FHWA). 2007. Special Report: Highway Construction
Noise: Measurement, Prediction, and Mitigation, Appendix A Construction Equipment
Noise Levels and Ranges. Internet URL:
www.fhwa.dot.gov/environment/noise/highway/hcn06.htm.
Fitts, Carmen. 2012. Personal communication via email to Mr. Josh McEnany (GSRC) from
Ms. Carmen Fitz (HDR). 31 July, 2012.
Immigration and Naturalization Services. 2001. Programmatic Environmental Impact
Statement for the Continuation of Immigration and Naturalization Service/Joint Task
Force – Six Operations, Port Arthur, Texas to San Diego, California.
Imperial County/BLM. 2012. Ocotillo Wind Energy Facility Final EIR. Sections available
online: http://www.icpds.com/?pid=2843 Accessed: May 9, 2012.
Imperial County, Office of Agricultural Commissioner. 2010. Agricultural Crop and Livestock
Report, 2010. Internet URL:
http://www.co.imperial.ca.us/ag/Crop_&_Livestock_Reports/Crop_&_Livestock_Report
_2010.pdf.
Midwest Research Institute. 1996. Improvement of Specific Emission Factors (BACM Project
No. 1) Prepared for South Coast Air Quality Management District. SCAQMD Contract
95040, Diamond Bar, CA. March 1996.
Salton Sea Authority. 2012. Prehistoric Native American Responses to Ancient Lake Cahuilla.
Internet URL: http://www.saltonsea.ca.gov/pdfs/hydrology/ancient_lake_cahuilla.pdf.
West Desert Road EA

Final
February 2013

00003828
6-3

San Diego State University. 2012. Ancient Lake Cahuilla, excerpted from Geology of the
Imperial Valley. Internet URL:
http://www.sci.sdsu.edu/salton/AncientLakeCahuilla.html.
U.S. Army Corps of Engineers (USACE). 1987. Corps of Engineers Wetlands Delineation.
U.S. Bureau of Labor Statistics. 2011. Economy at a Glance, El Paso, Texas MSA. Internet
URL: http://www.bls.gov/eag/eag.tx_elpaso_msa.htm.
U.S. Census Bureau. 2000. 2000 Decennial Census. Internet URL:
http://factfinder2.census.gov/.
U.S. Census Bureau. 2009. County Business Patterns, 2009 data. Internet URL:
http://censtats.census.gov/cgi-bin/cbpnaic/cbpsect.pl.
U.S. Census Bureau. 2010a. 2010 Decennial Census. Internet URL:
http://factfinder2.census.gov/.
U.S. Census Bureau. 2010b. American Community Survey (ACS), 5-Year Estimates, 20062010. Internet URL: http://factfinder2.census.gov/.
U. S. Customs and Border Patrol (CBP). 2012. Biological Survey for the West Desert Road
Calexico Station, El Centro Sector. GSRC biologist, Josh McEnany and John Ginter.
June 28, 2012.
U.S. Environmental Protection Agency. USEPA. 1974. Information on Levels of
Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate
Margin of Safety. Report 550/9-74-004.
USEPA. 2001. Procedures Document for National Emission Inventory, Criteria Air Pollutants
1985-1999. USEPA-454/R-01-006. Office of Air Quality Planning and Standards
Research Triangle Park NC 27711.
USEPA. 2009a. Frequently Asked Questions About NONROAD 2008. Office of
Transportation and Air Quality. USEPA-420-F-09-21, April 2009.
USEPA. 2009b. Policy Guidance on the Use of MOVES2010 for State Implementation Plan
Development, Transportation Conformity and Other Purposes. Office of Transportation
and Air Quality. USEPA-420-B-09-046.
USEPA. 2010. Reference, Table and Conversions, Inventory of U.S. Greenhouse Gas
Emissions and Sinks. Internet URL:
http://www.epa.gov/climatechange/emissions/usinventoryreport.html.
USEPA. 2012a. National Ambient Air Quality Standards (NAAQS). Internet URL:
http://www.epa.gov/air/criteria.html. Last Accessed. 4/11/2012.
West Desert Road EA

Final
February 2013

00003829
6-4

USEPA. 2012b. Welcome to the Green Book Nonattainment Areas for Criteria Pollutants.
Internet URL: www.epa.gov/oar/oaqps/greenbk.
USEPA. 2012c. Superfund; CERCLIS Hazardous Waste Sites. Internet URL:
http://cumulis.epa.gov/supercpad/cursites/srchrslt.cfm?Start=176&sortby=cnty. Last
Updated: March 2012.
United States Fish and Wildlife Service (USFWS). 2009. 50 CFR Part 17. Endangered and
Threatened Wildlife and Plants; Designation of Critical Habitat for Peninsular Bighorn
Sheep and Determination of a Distinct Population Segment of Desert Bighorn Sheep
(Ovis Canadensis nelsoni). Final Rule. Published April 14, 2009.
USFWS. 2012. Natural Resources of Concern, Imperial County California. Internet URL:
http://ecos.fws.gov/ipac/wizard/pdf/trustResourceListAsPdf!prepareAsPdf.action. Last
Accessed: May 2012.
USFWS. 2011. Flat-tailed Horned Lizard (Phrynosoma mcallii). Internet URL:
http://www.fws.gov/southwest/es/arizona/Flat.htm. U.S. Fish and Wildlife Service
Arizona Ecological Services. Last Updated May 2011. Last Accessed: July 2012.
U.S. Housing and Urban Development (HUD). 1984. 24 CFR Part 51 - Environmental Criteria
and Standards Sec. 51.103 Criteria and standards 44 FR 40861, July 12, 1979, as
amended at 49 FR 12214, Mar. 29, 1984.

West Desert Road EA

Final
February 2013

00003830

SECTION 7.0
ACRONYMS AND ABBREVIATIONS

00003831

00003832
7-1

7.0

ACRONYMS AND ABBREVIATIONS

ACEC
AOR
ASTM International
BEA
BIA
BLM
BMP
CAAQS
CalEPA
Caltrans
CARB
CBP
CBV
CDFG
CEPA
CEQ
CEQA
CERCLA
CFC
CFR
CH4
CO
CO2-E
CWA
dB
dBA
DHS
DNL
DOE
DOI
EA
EO
ESA
ESP
FEMA
FHWA
FM&E
FR
FTHL
GHG
GLO
GSRC
HFC
West Desert Road EA

Area of Critical Environmental Concern
Area of Responsibility
formerly known as American Society for Testing and Materials (ASTM)
Bureau of Economic Analysis
Bureau of Indian Affairs
Bureau of Land Management
Best Management Practices
California Ambient Air Quality Standards
California Environmental Protection Agency
California Department of Transportation
California Air Resources Board
U.S. Customs and Border Protection
Cross-Border Violators
California Department of Fish and Game
California Environment Protection Agency
Council on Environmental Quality
California Environmental Quality Act
Comprehensive Environmental Response, Compensation, and Liability
Act
chlorofluorocarbons
Code of Federal Regulations
methane
carbon monoxide
CO2 equivalent
Clean Water Act
Decibel
A-Weighted Decibel
Department of Homeland Security
Day-Night Sound Level
U.S. Department of Energy
U.S. Department of the Interior
Environmental Assessment
Executive Order
Endangered Species Act
Environmental Stewardship Plan
Federal Emergency Management Agency
Federal Highway Administration
Facilities Management and Engineering
Federal Register
Flat-tail horned lizard
greenhouse gases
General Land Office
Gulf South Research Corporation
hydrochlorofluorocarbons
Final
February 2013

00003833
7-2

HR
HUD
ICC
IID
INA
INS
IOs
IIRIRA
LCRV
M
mg/m3
MOU
MW
NAAQS
NAHC
NEPA
NO2
NOA
NOx
NRCS
NRHP
NPL
O3
Pb
PL
PM-10
PM-2.5
POE
POL
ppb
ppm
RCRA
ROI
ROW
RVSS
RWQCB
SHPO
SIP
SO2
SR
SWPPP
TI
TMDL
U.S.
USACE
USBP
West Desert Road EA

Hydrologic Region
U.S. Department of Housing and Urban Development
Interagency Coordinating Committee
Imperial Irrigation District
Immigration and Nationality Act
Immigration and Naturalization Service
isolated occurrences
Illegal Immigration Reform and Immigrant Responsibility Act
Lower Colorado River Valley
multiplying factor
milligram per cubic meter
Memorandum of Understanding
megawatt
National Ambient Air Quality Standards
Native American Heritage Commission
National Environmental Policy Act
nitrogen dioxide
Notice of Availability
nitrous oxide
Natural Resources Conservation Service
National Register of Historic Properties
National Priorities List
ozone
lead
Public Law
Particulate Matter <10 micrometers
Particulate Matter <2.5 micrometers
Ports of Entry
petroleum, oil, and lubricants
parts per billion
parts per million
Resource Conservation and Recovery Act
Region of Influence
Right-of-Way
Remote Video Surveillance System
California Regional Water Quality Control Board
State Historic Preservation Officer
state implementation plans
sulfur dioxide
State Route
Stormwater Pollution Prevention Plan
tactical infrastructure
total maximum daily load
United States
U.S. Army Corps of Engineers
U.S. Border Patrol
Final
February 2013

00003834
7-3

USC
USDA
USEPA
USFWS
USIBWC
VOC
VRM
YDMA
g/m3

West Desert Road EA

United States Code
U.S. Department of Agriculture
U.S. Environmental Protection Agency
U.S. Fish and Wildlife Service
U.S. Section, International Boundary and Water Commission
volatile organic compounds
Visual Resource Management
Yuma Desert Management Area
micrograms per cubic meter

Final
February 2013

00003835
7-4

THIS PAGE LEFT INTENTIONALLY BLANK

West Desert Road EA

Final
February 2013

00003836

SECTION 8.0
LIST OF PREPARERS

00003837

LIST OF PREPARERS

West Desert Road EA

USACE, Fort Worth

USACE, Fort Worth

CBP, FM&E

GSRC

GSRC

GSRC

GSRC

GSRC

GSRC

GSRC

GSRC

GSRC

Hope Pollmann

John Petrilla

Chris Ingram

Josh McEnany

David Hart

Missy Singleton

Ben Tomson

Rob Meyers

Steve Kolian

Ann Guissinger

Steve Oivanki

Agency/Organization

Richard Dill

Name

Geology/NEPA

Economics

Environmental Science

Environmental Science

Biology

Natural Resources

Archaeology

Forest Management

Biology/Ecology

5 years environmental
management

Environmental Protection
Specialist

Cultural resources surveys
EA preparation (Roadways and Traffic,
Sustainability and Greening, and Aesthetic
and Visual Resources)
EA preparation (Land Use, Geology and
Soils, Water Resources)
EA preparation (Vegetation, Wildlife, and
Protected Species)

17 years of professional
archaeology/cultural
resources studies
9 years of natural resources
and NEPA
2 years of natural resources
and NEPA
8 years of NEPA and natural
resources

20 years of natural resources
and NEPA

30 years economic analysis

EA preparation (Socioeconomics and
Environmental Justice and Protection of
Children)
EA preparation (Hazardous Materials and
Geology)

EA preparation (Air and Noise Resources)

Project management, EA preparation, and
biological surveys

12 years of natural resources
and NEPA

12 years of natural resources

EA review

33 years of EA/EIS studies

CBP project management, EA review and
coordination

USACE project management and EA
review

8 years environmental
management

Environmental Planning

Role in Preparing EA
USACE program management and EA
review

Experience
18 years engineering and
project management

Engineering Program
Manager

Discipline/Expertise

The following people were primarily responsible for preparing this EA.

8.0

00003838
8-1

Final
February 2013

00003839
8-2

THIS PAGE LEFT INTENTIONALLY BLANK

West Desert Road EA

Final
February 2013

00003840

APPENDIX A
CORRESPONDENCE

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Josh McEnany
Sent:
To:
Subject:

Wednesday, August 22, 2012 5:46 PM
PETRILLA, JOHN
Road Improvement Project along US/Mexico Border

In Reply Refer To:
FWSͲIMPͲ11B0229Ͳ12SL0539
Dear Mr. Petrilla,
This email is in response to your request, dated July 25, 2012, for information on federally listed, proposed, and
candidate species; critical habitat; sensitive and unique areas, and other resources that may occur in the vicinity of the
proposed road improvement project along the US/Mexico border in the Yuha Desert FlatͲtailed Horned Lizard
Management Area (FTHL MA), Imperial County, California.
Although we do not have siteͲspecific biological survey information, we are providing the following list of species known
to occur in the general area to assist your office in the preparation of a draft environmental assessment for the project.
Sensitive Species Within Project Area
FlatͲtailed horned lizard (Phrynosoma mcallii) Burrowing owl (Athene cunicularia) Golden Eagle (Aquila chrysaetos)
No designated critical habitat for federally listed species occurs within the project area.
Because the project area is within a designated FTHL MA, we recommend you adhere to the avoidance, minimization,
and mitigation measures outlined within the flatͲtailed horned lizard Rangewide Management Strategy (RMS) and you
coordinate closely with the Bureau of Land Management (BLM), El Centro office, to ensure you minimize flatͲtailed
horned lizard mortality from construction, operations, and maintenance of the road. A digital copy of the RMS is
available at: <http://www.fws.gov/southwest/es/arizona/Flat.htm> www.fws.gov/southwest/es/arizona/Flat.htm
We appreciate the opportunity to provide input on this project and are available to help develop measures to avoid and
minimize adverse impacts to trust resources that occur within your project area. If you have any questions, please feel
free to contact me Ͳ thanks!
*******************************************
Felicia M. Sirchia
Fish & Wildlife Biologist
U.S. Fish and Wildlife Service
Palm Springs Fish and Wildlife Office
777 E. Tahquitz Canyon Way, Suite 208
Palm Springs, CA 92262
Phone [phone] x205
Fax
760.322.4648

1

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00004014
Josh McEnany
From:
Sent:
To:
Subject:

Josh McEnany
Wednesday, January 02, 2013 9:54 AM
Josh McEnany
FW: Improvement and Construction, Operation and Maintenance in Imperial County

From: Julie Hagen [mailto:[e-mail]]
Sent: Thursday, December 27, 2012 8:14 AM
To: PETRILLA, JOHN
Cc: Raymond Cuero; Tina Estrada
Subject: Improvement and Construction, Operation and Maintenance in Imperial County

Good Morning,
Viejas Band of Kumeyaay Indians received your notice on improving an existing border road and we are concern with the
fact there are cultural resources in the vicinity. Viejas Band would like to know if there is going to be a Native American
Cultural monitor present when you are doing your improvements to help you with avoiding any impacts to cultural
resources. Thank you

Julie Hagen
Viejas Band of Kumeyaay Indians
Environmental Coordinator
Phone: [phone]
Cell: 619-890-2346

1

00004015

Section

General

Page

Location
Line

General

General

1

2

3

0

#

The U.S. Section International Boundary and Water Commission
(USIBWC) has responsibility through treaties between the United
States and Mexico to maintain the integrity of the border.
Included in the demarcation of the boundary through the
maintenance of permanent boundary monuments to include access
for their inspection and maintenance. Any proposed construction
must allow for line of sight visibility between each of the
boundary monuments. The USIBWC requires that all structures
be off-set from the international boundary by a minimum of 3 feet
and allow a clear line of sight between any affected boundary
monuments.
The USIBWC will not approve any construction near the
international boundary in the United States that increases,
concentrates, or relocates overland drainage flows into either
country.

The Native American Heritage Commission did conduct a Sacred
Lands File (SLF) search of its inventory and Native American
cultural resources were not identified in the location you specified.

Comment

December 2012

Thank you for your
comment, no structures
would be built as part of
the Proposed Action.

Thank you for your
comment and analyses.

CBP’s Response

Thank you for your
comment. No construction
or improvement activities
would increase, concentrate
or relocate any overland
drainages flowing into
either the United States or
Mexico.

John L. Merino,
Principal
Engineer,
USIBWC

Dave Singleton,
Program
Analyst, Native
American
Heritage
Commission

Reviewer

Public Comment Response Matrix
Draft EA for the Improvement and Construction, Operation, and Maintenance
of Proposed All-Weather Road in the El Centro Station Area of Responsibility,
U.S. Customs and Border Protection (CBP), El Centro Sector

John L. Merino,
Principal
Engineer,
USIBWC

00004016

3.2.1

8-10

6

3-4

General

5

Section

General

Page

Location
Line

4

#

The Cultural Resources Department of the Cocopah Indian Tribe
appreciates your consultation efforts on this project. We are
pleased that you contacted this department on this cultural
resource issue for the purpose of solicitation of our input and to
address our concerns on this matter. We concur with the Findings
of No Significant Impact (FONSI) determination made by your
agency. We would like to continue to be kept informed on the
progression of the project and be a apart of the consultation
process in the future.
On page 304, 3.2.1 Affected Environment, lines 8-10 state, “IID
has an extant gravel/sand quarry located near the eastern terminus
of the project area. This site is currently not in use; however, IID
could continue operations in the future.” (See Figure 3-1, page 35).” In 2012 IID relinquished the mineral materials sites and did
not renew the permit for gravel and clay out of the Mount Signal
Gravel Pit. The BLM concluded that the IID had completed all
the reclamation tasks and responsibilities associated with the
operation of the Mount Signal Gravel Pit and complied with all
BLM conditions an general stipulations. The Mount Signal
Gravel Pit is located within the Southwest Quarter of Section 24,
Township 17 South, Range 12 East, San Bernardino Meridian.

When available, the USIBWC requests the preliminary design
drawings and hydraulic studies be submitted to the USIBWC for
review and approval prior to begi nning any construction near the
international boundary.

Comment

December 2012

Thank you for your
comment and support.
CBP will keep the Cocopah
Indian Tribe informed as
the project moves forward.

Thank you for your
comment. Design
drawings for Phase A (2
Miles of All-Weather Road
Improvements from Mount
Signal Road moving West)
has been submitted to the
USIBWC for approval.
Phase B will be submitted
for approval prior to
construction activities
occurring.

CBP’s Response

The document has been
revised to reflect that IID
has no intention of using
the quarry site in the future.

Jill McCormick,
Cultural
Resource
Manager,
Cocopah Indian
Tribe

John L. Merino,
Principal
Engineer,
USIBWC

Reviewer

Public Comment Response Matrix
Draft EA for the Improvement and Construction, Operation, and Maintenance
of Proposed All-Weather Road in the El Centro Station Area of Responsibility,
U.S. Customs and Border Protection (CBP), El Centro Sector

Donald Vargas,
Environmental
Specialist,
Imperial
Irrigation
District

00004017

General

8

Section

General

Page

Location
Line

7

#
Reviewer

The project site lies outside the All-American Canal (AAC)
Service Area Boundary. Thus, the developer is ineligible to draw
water from the Westside Main Canal/AAC for this project and will
be required to contract water from a commercial source.

Viejas Band of Kumeyaay Indians received your notice on
improving an existing border road and we are concern with the
fact there are cultural resources in the vicinity. Viejas Band would
like to know if there is going to be a Native American Cultural
monitor present when you are doing your improvements to help
you with avoiding any impacts to cultural resources.

Donald Vargas,
Environmental
Specialist,
Imperial
Irrigation
District
Julie Hagen
Viejas Band of
Kumeyaay
Indians
Environmental
Coordinator

Comment

December 2012

Public Comment Response Matrix
Draft EA for the Improvement and Construction, Operation, and Maintenance
of Proposed All-Weather Road in the El Centro Station Area of Responsibility,
U.S. Customs and Border Protection (CBP), El Centro Sector

Native American monitors
will be onsite during
construction.

CBP will obtain its water
from a contract source.

CBP’s Response

00004018

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STATE OF CALIFORNIA – THE NATURAL RESOURCES AGENCY

EDMUND G. BROWN, JR., Governor

OFFICE OF HISTORIC PRESERVATION
DEPARTMENT OF PARKS AND RECREATION
rd

1725 23 Street, Suite 100
SACRAMENTO, CA 95816-7100
[phone] Fax: [phone]
[e-mail]
www.ohp.parks.ca.gov

December 20, 2012
Reply in Reference To: CBP_2012_1210_001
Christopher Colacicco, Director
Real Estate and Environmental Services
Border Patrol Facilities and Tactical Infrastructure
1301 Constitution Avenue, NW
EPA West Building, B-155
Washington, DC 20229
Re: Section 106 Consultation for Improvement, Construction, Operation and Maintenance of 1.6
Miles of All-Weather Road, Imperial County
Dear Director Colacicco:
Thank you for initiating consultation regarding the U.S. Customs and Border Protection’s (CBP) efforts
to comply with Section 106 of the National Historic Preservation Act of 1966 (16 U.S.C. 470f), as
amended, and its implementing regulation found at 36 CFR Part 800.
You have identified the undertaking as the construction, operation and maintenance of 1.6 miles
of all-weather road in Imperial County. Project activities include the improvement of a segment
of existing border road between Border Monuments 224 and 225 through widening, installation
of drainage features and new access road.
It is my understanding that Native American tribes have been notified about this project but no
comments have been received at this time. No listed or eligible National Register resources have been
identified within the project area and CBP is requesting my concurrence with their finding of no historic
properties affected. After reviewing the information submitted by CBP, I have no objection to this
finding. Please be advised that under certain circumstances, such as an unanticipated discovery or a
change in project description, you may have future responsibilities for this undertaking under 36 CFR
Part 800.
Thank you for seeking my comments and considering historic properties as part of your project
planning. If you have any questions or concerns, please contact Ed Carroll of my staff at (916) 4457006 or at email at [e-mail].
Sincerely,

Carol Roland-Nawi, PhD
State Historic Preservation Officer

00004031

00004032

APPENDIX B
BIOLOGICAL SURVEY REPORT

00004033

00004034
Biological Survey for the West Desert Road
El Centro Station, El Centro Sector
Dates Surveyed:
Climate:

June 28, 2012
Calm winds, Sunny, 85° F

Biologist:

Josh McEnany – Gulf South Research Corporation
John Ginter – Gulf South Research Corporation

U.S. Customs and Border Protection (CBP) is proposing the improvement, construction,
operation, and maintenance of approximately 2 miles of all-weather road along the U.S./Mexico
border within the U.S. Border Patrol (USBP) El Centro Station’s Area of Responsibility (AOR).
Currently, the existing road is impassable, which creates long drive times for agents to reach
patrol areas and restricts agents’ abilities to assist with interdictions and apprehensions. The
improvements to the West Desert Road begin at the Dump Turnaround (approximately N32°
38.993, W115° 41.996), near Border Monument 224, and extend to the Iron Gate (approximately
N32° 38.861, W115° 43.725), near Border Monument 225. The road would be improved to an
all-weather surface road (1.8 miles long) approximately 20 feet wide with 2-foot shoulders, and
would include any necessary drainage structures. A drag road would also be constructed along
the north side of the all-weather surface. Staging areas would be located approximately every
1/3 mile within the construction corridor and at the eastern and western terminuses. In addition
to the 1.8 miles of road improvement, a new access road leading to the BP Hill Remote Video
Surveillance System (RVSS) (approximately 0.2 mile) from the project road would be
constructed (Figure 1). The entire project corridor, which includes the new road to BP Hill, was
surveyed on foot (meandering transects) by biologists from Gulf South Research Corporation on
June 28, 2012. The survey limits varied from 200 to 300 feet wide, depending on the terrain and
suggestions by the project engineer. Vegetation, wildlife, and any potential waters of the United
States were identified and recorded as needed. Photographs taken during the field survey are
included in Attachment 1, and the location of each photo point is depicted on Figure 1.
The project lies in the Lower Colorado River Valley (LCRV) biome of the Sonoran Desert, and
the vegetation community is broadly classified as Sonoran Desert scrub (Brown 1994). The
project corridor contained less than five percent groundcover, and the predominant vegetation
observed was creosote bush (Larrea tridentata), which is typical for this area within the Sonoran
Desert. Other species observed included desert holly (Atriplex hymenelytra), skeleton weed
(Eriogonum deflexum), white bursage (Ambrosia dumosa), velvet mesquite (Prosopis velutina),
and catclaw acacia (Acacia greggii). Table 1 includes the full list of plant species observed
during the survey.
The Sonoran Desert is extremely hot, and many animals are nocturnal or crepuscular. Many of
the animals that inhabit the Sonoran Desert are found throughout the warmer and drier regions of
the southwestern United States (Brown 1994). Common mammals found in this habitat include
multiple species of bats, coyote (Canis latrans), black-tailed jack-rabbit (Lepus californicus),
desert pocket mouse (Chaetodipus penicillatus), road runner (Geococcyx californianus),
mourning dove (Zenaida macroura), lesser nighthawk (Chordeiles acutipennis), and desert
iguana (Dipsosaurus dorsalis). The most common wildlife observed during the survey

1

Figure 1: Survey Map

·

0

400

800

1,200
Feet

Staging Areas

2
Project Location

Access Road

Photo Points

)
"

"
)

Wash Crossings

!
(

Project Location

May 2012

00004035

00004036
Table 1. Plant Species Observed During the West Desert Road Survey
Common Name

Scientific Name

Velvet mesquite
Desert holly
Cattle saltbush
Desert trumpet
Catclaw acacia
Skeleton weed
White bursage
Sahara mustard
Desert Indianwheat
White ratany
Sweetbush
Devil’s spineflower
Desert lavender
Wild heliotrope
Arabian schismus
Sixweeks fescue
California threeawn
Desert smoketree
Dyebush
Jointfir
Fanleaf crinklemat
Creosote bush

Prosopis velutina
Atriplex hymenelytra
Atriplex polycarpa
Eriogonum inflatum
Acacia greggii
Eriogonum deflexum
Ambrosia dumosa
Brassica tournefortii
Plantago ovate
Krameria grayi
Bebia juncea
Chorizanthe rigida
Hyptis emoryi
Phacelia crenulata
Schismus arabicus
Vulpia octoflora
Aristida californica
Psorothamnus spinosor
Psorothamnus emoryi
Ephedra nevadensis
Tiquilia plicata
Larrea tridentata

includes mourning dove, lesser nighthawk, black-throated sparrow (Amphispiza bilineata), tiger
whiptail (Aspidoscelis tigris), and long-tailed brush lizard (Urosuarus graciosus). All of the
wildlife species observed during the survey are included in Table 2.
Table 2. Wildlife Observed During the West Desert Road Survey
Common Name

Scientific Name

Black-throated sparrow
Lesser nighthawk
Mourning dove
Red-tailed hawk
Flat-tail horned lizard*
Desert kangaroo rat*
Coyote*
Kit fox*
Sidewinder*
Tiger whiptail
Desert iguana
Zebra-tailed lizard
Long-tailed brush lizard

Amphispiza bilineata
Chordeiles acutipennis
Zenaida macroura
Buteo jamaicensis
Phrynosoma mcallii
Dipodomys deserti
Canis latrans
Vulpes macrotis
Crotalus cerastes
Aspidoscelis tigris
Dipsosuarus dorsalis
Callisaurus draconoides
Urosuarus graciosus

*These species were not observed; however, tracks and/or scat were observed within the project corridor.

The survey identified seven ephemeral washes bisecting the project corridor that might be
regulated as waters of the United States (Figure 1). The total impact on the seven potential
waters of the United States would be less than 0.1 acre. Dominant plants found along the
drainages include velvet mesquite, catclaw acacia, and skeleton weed.
3

00004037
Although no Federally listed or state-listed species were observed during the surveys, tracks and
scat of the flat-tail horned lizard (Phrynosoma mcallii) (FTHL) were recorded at one location.
FTHL, a conservation agreement species, is not a Federally protected species. However, five
Federal agencies signed a Memorandum of Agreement to protect the FTHL and its habitat on
Federal lands. Habitat for the FTHL exists within the project corridor in the Yuma Desert
Management Area (YDMA). Established by the 1997 Flat-Tailed Horned Lizard Rangewide
Management Strategy, the YDMA serves as a tool to facilitate FTHL conservation. The project
area is located within the YDMA. One burrow complex, presumably inhabited by desert
kangaroo rats (Dipodomys deserti) and which could provide habitat for the BLM listed western
burrowing owl (Athene cunicularia) and kit fox (Vulpes macrotis), was also observed and
recorded during the survey efforts (Figure 1).
References
Brown, D. E. (ed.). 1994. Biotic Communities: Southwestern United States and Northwestern
Mexico. Salt Lake City, UT: University of Utah Press.

4

00004038

ATTACHMENT 1

00004039

00004040

Photograph Point 1. Facing West

Photograph Point 1. Facing North

00004041

Photograph Point 1. Facing East

Photograph Point 2. Facing West

00004042

Photograph Point 2. Facing North

Photograph Point 3. Facing East

00004043

Photograph Point 3. Facing Southeast

Photograph Point 3. Facing East

00004044

Photograph Point 4. Facing West

Photograph Point 4. Facing Southeast

00004045

Photograph Point 5. Facing Southwest

Photograph Point 5. Facing Northeast

00004046

Photograph Point 6. Facing North

Photograph Point 6. Facing West

00004047

Photograph Point 6. Facing East

Photograph Point 6. Facing South

00004048

Photograph Point 7. Facing North

Photograph Point 8. Facing South

00004049

Photograph Point 8. Facing North

Photograph Point 9. Facing South

00004050

Photograph Point 9. Facing North

Photograph Point 10. Facing North

00004051

Photograph Point 10. Facing West

Photograph Point 11. Facing Southwest

00004052

Photograph Point 12. Facing Northeast

Photograph Point 12. Facing North

00004053

Photograph Point 13. Facing South

00004054

APPENDIX C
PROTECTED SPECIES: FEDERAL, STATE, AND BLM SENSITIVE

00004055

00004056

00004057

00004058

Abronia villosa var. aurita
Astragalus magdalenae var. peirsonii
Chaenactis glabriuscula var. orcuttiana
Chamaesyce platysperma
Chorizanthe polygonoides var. longispina
Croton wigginsii
Cylindropuntia fosbergii
Cylindropuntia munzii
Dieteria asteroides var. lagunensis
Fremontodendron mexicanum
Grindelia hallii
Helianthus niveus subsp. tephrodes
Hulsea californica
Lupinus excubitus var. medius
Monardella nana subsp. leptosiphon
Palafoxia arida var. gigantea
Pholisma sonorae
Streptanthus campestris
Symphyotrichum defoliatum
Thermopsis californica var. semota
Thysanocarpus rigidus
Xylorhiza orcuttii

SCIENTIFIC NAME
chaparral sand-verbena
Peirson's milk-vetch
Orcutt's pincushion
flat-seeded spurge
long-spined spineflower
Wiggins' croton
pink teddy-bear cholla
Munz cholla
Mount Laguna aster
Mexican flannelbush
San Diego gumplant
Algodones Dunes sunflower
San Diego sunflower
Mountain Springs bush lupine
San Felipe monardella
giant Spanish needle
sand food
southern jewel-flower
San Bernardino aster
velvety false lupine
Ridge Fringepod
Orcutt's woody aster

COMMON NAME
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant
Vascular Plant

TYPE OF PLANT

BLM Special Status Plants under the jurisdiction of the El Centro Field Office as of September 18, 2012.

Nyctaginaceae
Fabaceae
Asteraceae
Euphorbiaceae
Polygonaceae
Euphorbiaceae
Cactaceae
Cactaceae
Asteraceae
Malvaceae
Asteraceae
Asteraceae
Asteraceae
Fabaceae
Lamiaceae
Asteraceae
Boraginaceae
Brassicaceae
Asteraceae
Fabaceae
Brassicaceae
Asteraceae

FAMILY
BLM Sensitive
Federal Threatened
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
Federal Endangered
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive
BLM Sensitive

STATUS

KNOWN OR SUSPECTED ON
BLM LANDS?
Suspected on BLM lands
Known on BLM lands
Suspected on BLM lands
Suspected on BLM lands
Suspected on BLM lands
Known on BLM lands
Known on BLM lands
Known on BLM lands
Known on BLM lands
Known on BLM lands
Known on BLM lands
Known on BLM lands
Known on BLM lands
Known on BLM lands
Suspected on BLM lands
Known on BLM lands
Known on BLM lands
Suspected on BLM lands
Suspected on BLM lands
Suspected on BLM lands
Suspected on BLM lands
Known on BLM lands

00004059

00004060
El Centro Faunal Sensitive Species 2011
MAMMALS
California leafͲnosed bat
Cave myotis
Desert bighorn sheep
Fringed myotis
LongͲeared myotis
Pallid bat
Palm Springs little pocket mouse
SmallͲfooted myotis
Townsend's bigͲeared bat
Western mastiffͲbat
Yuma myotis

Macrotus californicus
Myotis velifer
Ovis canadensis nelsoni
Myotis thysanodes
Myotis evotis
Antrozous pallidus
Perognathus longimembris bangsi
Myotis ciliolabrum
Corynorhinus townsendii
Eumops perotis californicus
Myotis yumanensis

BIRDS
Brown pelican
Burrowing owl
California black rail
California spotted owl
Elf owl
Gila woodpecker
Mountain plover
Tricolored blackbird
Western yellowͲbilled cuckoo

Pelecanus occidentalis
Athene cunicularia
Laterallus jamaicensis coturniculus
Strix occidentalis occidentalis
Micrathene whitneyi
Melanerpes uropygialis
Charadrius montanus
Agelaius tricolor
Coccyzus americanus occidentalis

REPTILES
Barefoot banded gecko
Colorado Desert fringeͲtoed lizard
FlatͲtailed horned lizard

Coleonyx switaki
Uma notata notata
Phrynosoma mcalli
Actinemys (=Clemmys) marmorata
Pallid

Southwestern pond turtle
TwoͲstriped garter snake

Thamnophis hammondii

00004061
AMPHIBIANS
Couch's spadefoot toad
Lowland leopard frog

Scaphiopus couchi
Lithobates (=Rana) yavapaiensis

00004062
State of California
The Natural Resources Agency
DEPARTMENT OF FISH AND GAME
Biogeographic Data Branch
California Natural Diversity Database
STATE & FEDERALLY LISTED ENDANGERED & THREATENED ANIMALS OF CALIFORNIA
January 2011
This is a list of animals found within California or off the coast of the State that have been classified as Endangered or Threatened by the
California Fish & Game Commission (state list) or by the U.S. Secretary of the Interior or the U.S. Secretary of Commerce (federal list).
The official California listing of Endangered and Threatened animals is contained in the California Code of Regulations, Title 14,
Section 670.5. The official federal listing of Endangered and Threatened animals is published in the Federal Register, 50 CFR 17.11.
The California Endangered Species Act of 1970 created the categories of “Endangered” and “Rare”. The California Endangered Species
Act of 1984 created the categories of “Endangered” and “Threatened”. On January 1, 1985, all animal species designated as “Rare”
were reclassified as “Threatened”.
Animals that are candidates for state listing and animals proposed for federal listing are also included on this list. A state candidate
species is one that the Fish and Game commission had formally noticed as being under review by the Department for addition to the
State list. A federal proposed species is one for which a proposed regulation has been published in the Federal Register.
Code Designation:

Totals as of January 2011

SE = State-listed as Endangered
ST = State listed as Threatened
SR = State listed as Rare – old designation, all animals reclassified to Threatened on 1/1/85
FE = Federally listed as Endangered (21.2% of all U.S. listed endangered animals as of 1/10/11)
FT = Federally listed as Threatened (24.4% of all U.S. listed threatened animals as of 1/10/11)
SCE = State candidate (Endangered)
SCT = State Candidate (Threatened)
SCD = State Candidate (Delisting)
FPE = Federally proposed (Endangered)
FPT = Federally proposed (Threatened)
FPD = Federally proposed (Delisting)
Total number of animals listed (includes subspecies & population segments)
Total number of candidate/proposed animals for listing
Number of animals State listed only
Number of animals Federally listed only
Number of animals listed under both State & Federal Acts

46
35
0
88
40
2
0
1
1
1
0
157
4
31
71
55

Common and scientific names are shown as they appear on the state or federal lists. If the nomenclature differs for a species that is
included on both lists, the state nomenclature is given and the federal nomenclature is shown in a footnote. Synonyms, name changes,
and other clarifying points are also footnoted.
Critical Habitat is defined in Section 3 of the federal Endangered Species Act as specific areas, both occupied and unoccupied, that is
essential to the conservation of a listed species and that may require special management considerations or protection.
Recovery Plans are discussed in Section 4 of the federal Endangered Species Act. Each plan incorporates site-specific management
actions necessary for the conservation and survival of the species.
The “List Date” for final federal listing and final Critical Habitat designation is the date the listing or designation becomes effective, this
is usually not the date of publication of the rule in the Federal Register; it is usually about 30 days after publication, but may be longer.
If a taxa that was previously listed or proposed for listing no longer has any listing status the entry has been grayed out.
For taxa that have more than one status entry, the current status is in bold and underlined.
Changes to this update of the list are denoted by *

00004063
Endangered and Threatened Animals of California

LISTING STATUS

CRITICAL
HABITAT

RECOVERY
PLAN

1-17-95

Final

3-09-01

Final

1998

FE

6-28-01

Not
prudent

6-28-01

Final

2008

FE

ST2

Federal

Effective
List
Date
Designation

FE

State

List
Date

2-13-09

*Proposed

9-28-10

Final3

5-12-05
4-27-04
6-29-01
2-10-06
12-28-04
8-06-03
9-24-02
2-10-06
12-28-04
8-06-03
9-24-02
2-10-06
12-28-04
8-06-03
9-24-02
1-11-08
4-22-03
10-23-00
2-10-06
12-28-04
8-06-03
9-24-02

Final

1998

Final

2005

Final

2005

Final

2005

Final

1998

Final

2005

Effective
Date
Version

10-02-80

Date

GASTROPODS
Trinity bristle snail
Monadenia setosa1
Morro shoulderband (=banded dune) snail
Helminthoglypta walkeriana
White abalone
Haliotis sorenseni
Black abalone
Haliotis cracherodii
CRUSTACEANS
Riverside fairy shrimp
Streptocephalus woottoni

FE

Conservancy fairy shrimp
Branchinecta conservatio

FE

8-03-93

Proposed

9-19-94

Final
Final4
Proposed

Final
Proposed

Longhorn fairy shrimp
Branchinecta longiantenna

FE

9-19-94

Final 4
Proposed

Final
Proposed

Vernal pool fairy shrimp
Branchinecta lynchi

FT

9-19-94

Final 4
Proposed

Final
Proposed

San Diego fairy shrimp
Branchinecta sandiegoensis

FE

Vernal pool tadpole shrimp
Lepidurus packardi

FE

2-03-97

Final
Proposed5

9-19-94

Final
Final 4
Proposed

Final
Proposed

Shasta crayfish
Pacifastacus fortis

SE
ST

2-26-88
10-02-80

FE

9-30-88

Final

1998

California freshwater shrimp
Syncaris pacifica

SE

10-02-80

FE

10-31-88

Final

1998

FE

2-24-97

Final

1998

INSECTS
Zayante band-winged grasshopper
Trimerotropis infantilis

Final

3-09-01

1

Current taxonomy is Monadenia infumata setosa.
On January 1, 1985, all species designated as “rare” were reclassified as “threatened”, as stipulated by the California Endangered Species Act.
3
The Federal Circuit Court vacated critical habitat for the Riverside fairy shrimp on 10-30-02. The judge instructed the USFWS to begin the process of re-designating
critical habitat for this species. New critical habitat was proposed 4-27-04 and finalized effective 5-12-05.
4
On October 28, 2004 the courts ordered the USFWS to reconsider the areas excluded from the final critical habitat designation made August 6, 2003. The December 28
2004 proposed rule is only for lands previously excluded and does not affect the areas included in the August 6, 2003 final rule. The non-economic exclusions made to the
August 6, 2003 final rule were confirmed effective March 8, 2005
5
Due to court order the previously designated critical habitat was vacated and the USFWS was directed to re-proposed critical habitat.
2

2

January 2011

00004064
Endangered and Threatened Animals of California

LISTING STATUS

State
Mount Hermon June beetle
Polyphylla barbata
Casey’s June beetle
Dinacoma caseyi
Delta green ground beetle
Elaphrus viridis
Valley elderberry longhorn beetle
Desmocerus californicus dimorphus
Ohlone tiger beetle
Cicindela ohlone
Kern primrose sphinx moth
Euproserpinus euterpe
Mission blue butterfly
Icaricia icarioides missionensis6
Lotis blue butterfly
Lycaeides argyrognomon lotis7
Palos Verdes blue butterfly
Glaucopsyche lygdamus palosverdesensis
El Segundo blue butterfly
Euphilotes battoides allyni
Smith’s blue butterfly
Euphilotes enoptes smithi
San Bruno elfin butterfly
Callophrys mossii bayensis
Lange’s metalmark butterfly
Apodemia mormo langei
Bay checkerspot butterfly
Euphydryas editha bayensis

List
Date

CRITICAL
HABITAT

RECOVERY
PLAN

Federal
FE

Effective
List
Date
Designation
2-24-97

FPE

7-09-09

Proposed

7-09-09

FT

8-08-80

Final

8-08-80

FT

8-08-80

Final

8-08-80

FE

10-03-01

FT

4-08-80

Proposed

FE

6-01-76

FE

Effective
Date
Version
Final

Date
1998

Final
Final
Final

2006
1985
1984

Final

1998

7-03-78

Final

1984

Proposed

2-08-77

Final

1984

6-01-76

Proposed

2-08-77

Final

1985

FE

7-02-80

Final

7-02-80

Final

1984

FE

6-01-76

Proposed

2-08-77

Final

1998

FE

6-01-76

Proposed

2-08-77

Final

1984

FE

6-01-76

Proposed

2-08-77

Final

1984

FE

6-01-76

Proposed

2-08-77

Revised

1984

FT

10-18-87

Final

9-25-08
8-22-07
5-30-01
1-17-08
5-15-02
2-07-01

Final

1998

Final

2003

Final
Draft

2007
2005

Draft

2004

Revised

2001

Proposed

Final
Proposed8

Quino checkerspot
Euphydras editha quino (=E.e.wrighti)

FE

1-16-97

Carson wandering skipper
Pseudocopaeodes enus obscurus
Laguna Mountains skipper
Pyrgus ruralis lagunae
Callippe silverspot butterfly
Speyeria callippe callippe
Behren’s silverspot butterfly
Speyeria zerene behrensii
Oregon silverspot butterfly9
Speyeria zerene hippolyta
Myrtle’s silverspot butterfly
Speyeria zerene myrtleae
Delhi Sands flower-loving fly
Rhaphiomidas terminatus abdominalis

FE

8-07-02

FE

1-16-97

Final

1-11-07

FE

12-05-97

Proposed

3-28-80

FE

12-05-97

FT

7-02-80

FE

6-22-92

Final

1998

FE

9-23-93

Final

1997

Final
Proposed

Final

7-02-80

6

Current taxonomy is Plebejus icarioides missionensis
Current taxonomy is Plebejus idas lotis
8
Proposed rule is to revise designated Critical Habitat
9
Current common name is Hippolyta frittilary
7

3

January 2011

00004065
Endangered and Threatened Animals of California

LISTING STATUS

CRITICAL
HABITAT

Federal

Effective
List
Date
Designation

FT10

State

List
Date

6-06-06

RECOVERY
PLAN
Effective
Date
Version

Date

FISHES
Green sturgeon – southern DPS
Acipenser medirostris
Chinook salmon-Winter-run11
Oncorhynchus tshawytscha

Final
Proposed

9-22-89

Chinook salmon-California coastal ESU13
Oncorhynchus tshawytscha

FE12
FE

8-29-05
2-03-94

Final

FT14
FT15

SE

8-29-05
11-15-99

Final

11-09-09
9-08-08
3-23-99

Draft

2009
1997

Draft

2009

Final
(state)

2004

2004

Final
Final

1-02-06
12-10-04
4-30-02
2-16-00
1-02-06
12-10-04
4-30-02
2-16-00
6-04-99

8-29-05
6-05-97

Final

3-17-00

Final
(state)

FT

4-13-78

Final

4-13-78

Exempt

Lahontan cutthroat trout
Oncorhynchus clarki henshawi
Paiute cutthroat trout
Oncorhynchus clarki seleniris

FT
FE
FT
FE

7-16-75
10-13-70
7-16-75
3-11-6725

Steelhead-Northern California DPS26 27
Oncorhynchus mykiss

FT28
FT

2-06-06
8-07-00

Proposed
Rescinded

Chinook salmon-Spring-run
Oncorhynchus tshawytscha

16

ST

2-05-99

17

FT
FT18

8-29-05
11-15-99

Final
Final
Proposed
Rescinded

Coho salmon-Central California Coast ESU
Oncorhynchus kisutch

19

20

SE

3-30-05

FE
FT21

8-29-05
12-02-96

Coho salmon-So. Oregon/No. Calif ESU
Oncorhynchus kisutch

ST22

3-30-05

FT23
FT24

Little Kern golden trout
Oncorhynchus mykiss whitei

Final
Revised
Final
Final
Proposed

1995
2004
1985

1-02-06
12-10-04

10

Includes all spawning populations south of the Eel River
Federal: Sacramento River winter run Chinook salmon
12
The NMFS has completed comprehensive status reviews for 27 west coast salmon & steelhead ESUs, 10 of these in California. The 29 Aug 2005 list date refers to the
final designations made as a result of those status reviews.
13
ESU = Evolutionarily Significant Unit
14
The NMFS has completed comprehensive status reviews for 27 west coast salmon & steelhead ESUs, 10 of these in California. The 29 Aug 2005 list date refers to the
final designations made as a result of those status reviews.
15
Naturally spawned coastal spring & fall Chinook salmon between Redwood Creek in Humboldt County & the Russian River in Sonoma County.
16
State listing is for the Sacramento River drainage.
17
The NMFS has completed comprehensive status reviews for 27 west coast salmon & steelhead ESUs, 10 of these in California. The 29 Aug 2005 list date refers to the
final designations made as a result of those status reviews.
18
Federal: Central Valley Spring-Run ESU. Includes populations spawning in the Sacramento River & its tributaries.
19
The Coho south of San Francisco Bay were state listed in 1995; in February 2004 the Fish and Game Commission determined that the Coho from San Francisco to
Punta Gorda should also be listed as Endangered. This changed was finalized by of Office of Administrative Law on March 30, 2005.
20
The NMFS has completed comprehensive status reviews for 27 west coast salmon & steelhead ESUs, 10 of these in California. The 29 Aug 2005 list date refers to the
final designations made as a result of those status reviews.
21
The Federal listing is limited to naturally spawning populations in streams between Punta Gorda, Humboldt County & the San Lorenzo River, Santa Cruz County.
22
The Fish and Game Commission determined that the Coho from Punta Gorda to the Oregon border should be listed as Threatened on February 25, 2004. This
determination was finalized by the Office of Administrative Law on March 30, 2005.
23
The NMFS has completed comprehensive status reviews for 27 west coast salmon & steelhead ESUs, 10 of these in California. The 29 Aug 2005 list date refers to the
final designations made as a result of those status reviews.
24
The Federal listing is for populations between Cape Blanco, Oregon & Punta Gorda, California.
25
All species with a list date of 03-11-67 were listed under the Endangered Species Preservation Act of Oct 15, 1966.
11

4

January 2011

00004066
Endangered and Threatened Animals of California

LISTING STATUS

State

List
Date

Steelhead-Central California Coast DPS29
Oncorhynchus mykiss

Federal
FT30
FT

Steelhead-South/Central Calif Coast DPS31
Oncorhynchus mykiss

FT32
FT

Steelhead-Southern California DPS33
Oncorhynchus mykiss

FE34
FE

Steelhead-Central Valley DPS35
Oncorhynchus mykiss

FT36
FT

Bull trout
Salvelinus confluentus

SE

Delta smelt
Hypomesus transpacificus
Longfin smelt
Spirinchus thaleichthys
Eulachon – southern DPS
Thaleichthys pacificus
Mohave tui chub
Gila bicolor mohavensis38
Owens tui chub
Gila bicolor snyderi39
Cowhead Lake tui chub
Gila bicolor vaccaceps

SE
ST
ST
SCE

10-02-80

FT

CRITICAL
HABITAT

RECOVERY
PLAN

Effective
List
Effective
Date
Designation Date
Version
2-06-06
Final
1-02-06
Proposed 12-10-04
10-17-97
Rescinded 4-30-02
Final
3-17-00
1-02-06
2-06-06
Final
Proposed 12-10-04
10-17-97
Rescinded 4-30-02
Final
3-17-00
2-06-06
Final
1-02-06
Draft
Proposed 12-10-04
10-17-97
Rescinded 4-30-02
Final
3-17-00
2-06-06
Final
1-02-06
Draft
Proposed 12-10-04
5-18-98
Rescinded 4-30-02
Final
3-17-00
*Proposed 1-14-10
12-01-99
37

2009

2009

(revised)

Final
FT

3-05-93

Final

10-26-05
12-19-94

FT

1-20-10
12-09-93
4-09-10
2-02-08

Date

5-17-10

*Proposed

1-05-11

SE

6-27-71

FE

SE

1-10-74

FE

8-05-85

withdrawn

1996

Final

10-13-70

Final

1984

Final

1998

10-11-06
3-30-98

FPE

Final

8-05-85

26

Naturally spawned populations residing below impassable barriers in coastal basins from Redwood Creek in Humboldt County to, and including, the Gualala River in
Mendocino County.
27
DPS = Distinct Population Segment
28
The NMFS has completed comprehensive status reviews for 27 west coast salmon & steelhead ESUs. The 6 Feb 2006 list date refers to the final designations made as a
result of those status reviews. There was no change in listing status for the steelhead ESUs in California.
29
Coastal basins from the Russian River, south to Soquel Creek, inclusive. Includes the San Francisco & San Pablo Bay basins, but excludes the Sacramento-San Joaquin
River basins.
30
The NMFS has completed comprehensive status reviews for 27 west coast salmon & steelhead ESUs. The 6 Feb 2006 list date refers to the final designations made as a
result of those status reviews. There was no change in listing status for the steelhead ESUs in California.
31
Coastal basins from the Pajaro River south to, but not including, the Santa Maria River.
32
The NMFS has completed comprehensive status reviews for 27 west coast salmon & steelhead ESUs. The 6 Feb 2006 list date refers to the final designations made as a
result of those status reviews. There was no change in listing status for the steelhead ESUs in California.
33
Coastal basins from the Santa Maria River (inclusive), south to the U.S.-Mexico Border.
34
The NMFS has completed comprehensive status reviews for 27 west coast salmon & steelhead ESUs. The 6 Feb 2006 list date refers to the final designations made as a
result of those status reviews. There was no change in listing status for the steelhead ESUs in California.
35
The Sacramento and San Joaquin Rivers and their tributaries.
36
The NMFS has completed comprehensive status reviews for 27 west coast salmon & steelhead ESUs. The 6 Feb 2006 list date refers to the final designations made as a
result of those status reviews. There was no change in listing status for the steelhead ESUs in California.
37
There is no designated or proposed Critical Habitat for bull trout in California.
38
Current taxonomy: Siphateles bicolor mohavensis
39
Current taxonomy: Siphateles bicolor snyderi

5

January 2011

00004067
Endangered and Threatened Animals of California

LISTING STATUS

State
Tecopa pupfish (Extinct)
Cyprinodon nevadensis calidae
Bonytail40
Gila elegans
Sacramento splittail
Pogonichthys macrolepidotus
Colorado squawfish42
Ptychocheilus lucius

delisted

SE
SE
SR

List
Date
1987
6-27-71
1-10-74
6-27-71

Federal
delisted

FE
FE
deleted41

FT

CRITICAL
HABITAT

RECOVERY
PLAN

Effective
List
Effective
Date
Designation Date
Version Date
1-15-82
10-13-70
4-23-80
Final
3-21-94
Revised 2002
Revised 1990
9-22-03
3-10-99
3-11-67
Final
3-21-94
Revised 2002
Revised 1991

SE

6-27-71

FE

Lost River sucker
Deltistes luxatus

SE
SR

1-10-74
6-27-67

FE

7-18-88

Proposed

12-01-94

Final

Modoc sucker
Catostomus microps

SE
SR

10-02-80
1-10-74

FE

6-11-85

Final

6-11-85

Exempt

FT43

5-12-00

*Final

1-13-11
12-09-09

Santa Ana sucker
Catostomus santaanae

Proposed
(revised)

Final
Shortnose sucker
Chasmistes brevirostris
Razorback sucker
Xyrauchen texanus

SE
SR
SE
SR

1-10-74
6-27-71
1-10-74
6-27-71

FE

7-18-88

Proposed

2-03-05
12-01-94

FE

10-23-91

Final

Desert pupfish
Cyprinodon macularius

SE

10-02-80

FE

3-31-86

Final

Cottonball Marsh pupfish
Cyprinodon salinus milleri
Owens pupfish
Cyprinodon radiosus
Thicktail chub (Extinct)
Gila crassicauda
Unarmored threespine stickleback
Gasterosteus aculeatus williamsoni

ST

1-10-74

SE

6-27-71

FE

3-11-67

delisted

10-02-80
1-10-74
6-27-71

FE

10-13-70

1993

SE
SE

Final

1993

3-21-94

Revised
Final

2002
1998

3-31-86

Final

1993

Final

1998

Final

1985

Tidewater goby
Eucyclogobius newberryi

Rough sculpin
Cottus asperrimus

45

FPD
FE
ST

12-09-02
6-24-99
2-04-94

Final

2005

9-17-02

Proposed
Withdrawn

Designati
on should
not be
made 44

11-17-80
3-03-08
11-28-06
11-20-00

Final
Proposed

Final

1-10-74

40

Federal: Bonytail chub
On 23 June 2000, the Federal Eastern District Court of Calif. found the final rule to be unlawful and on 22 Sept 2000 remanded the determination back to the USFWS
for a reevaluation of the final decision. After a thorough review the USFWS removed the Sacramento splittail from the list of threatened species.
42
Current nomenclature and federal listing: Colorado pikeminnow
43
Populations in the Los Angeles, San Gabriel and Santa Ana River basins.
44
Full explanation of this situation is given in the Federal Register notice.
45
Proposal to delist refers to populations north of Orange County only.
41

6

January 2011

00004068
Endangered and Threatened Animals of California

LISTING STATUS

State

List
Date

CRITICAL
HABITAT

Federal

Effective
List
Date
Designation

FT48

9-03-04

RECOVERY
PLAN
Effective
Date
Version

Date

AMPHIBIANS
California tiger salamander (central valley
DPS)
Ambystoma californiense
California tiger salamander (Santa Barbara
County DPS)
Ambystoma californiense
California tiger salamander (Sonoma
County DPS)
Ambystoma californiense
Santa Cruz long-toed salamander
Ambystoma macrodactylum croceum
Siskiyou Mountains salamander
Plethodon stormi
Scott Bar salamander
Plethodon asupak
Techachapi slender salamander
Batrachoseps stebbinsi
Kern Canyon slender salamander
Batrachoseps simatus
Desert slender salamander
Batrachoseps aridus54
Shasta salamander
Hydromantes shastae
Limestone salamander
Hydromantes brunus
Black toad
Bufo exsul55
Arroyo toad56
Bufo californicus57

ST4647

5-20-10

Final49
Proposed
50

9-22-05
8-10-04

(ST)

FE 48

9-15-00

Final51

11-24-04

(ST)

FE 48

3-19-03

Proposed
52

8-18-09
8-02-05

FE

3-11-67

Proposed

6-22-78

FE

6-04-73

FE

1-17-95

SE

6-27-71

SCD
ST
ST53

9-30-05
6-27-71
6-27-71

ST

6-27-71

ST

6-27-71

SE

6-27-71

ST

6-27-71

ST

6-27-71

ST

6-27-71
(Revised)

Final
Proposed
58

Final

10-13-09
5-13-05
2-14-05
4-27-04
3-09-01

1999

Final

Proposed

Draft

1982

Final

1999

46

The state listing refers to the entire range of the species.
The Office of Administrative Law approved the listing on Aug 2, 2010. The regulations become effective on Aug 19, 2010.
48
In 2004 the California tiger salamander was listed as “threatened” statewide. The Santa Barbara County and Sonoma County Distinct Vertebrate Population Segments
(DPS), formerly listed as “endangered”, were reclassified to “threatened”. On Aug 19 2005 U.S. District court vacated the downlisting of the Sonoma and Santa Barbara
populations from “endangered” to “threatened”. Therefore, the Sonoma & Santa Barbara populations are once again listed as “endangered”
49
Final rule published Aug 23, 2005 is for the central valley population only.
50
Critical Habitat proposal published Aug 10, 2004 is for the central valley population only.
51
Final rule published Nov 24, 2004 is for the Santa Barbara County population only.
52
Proposed rule published Aug 2, 2005 is for the Sonoma County population only. The proposed rule published Aug 18, 2009 encompasses the same geographic area as
the Aug 2, 2005 proposal.
53
Since this newly described species was formerly considered to be a subpopulation of Plethodon stormi, and since Plethodon stormi is listed a Threatened under the
California Endangered Species Act (CESA), Plethodon asupak retains the designation as a Threatened species under CESA.
54
Current taxonomy: Batrachoseps major aridus.
55
Current taxonomy: Anaxyrus exsul
56
Former taxonomy: Bufo microscaphus californicus.
57
Current taxonomy: Anaxyrus californicus
47

7

January 2011

00004069
Endangered and Threatened Animals of California

LISTING STATUS

State

List
Date

California red-legged frog59
Rana aurora draytonii
Mountain yellow-legged frog – Southern
California DPS6162
Rana muscosa

*SCE
or
SCT63

9-21-10

Mountain yellow-legged frog
Rana sierrae

*SCE
or
SCT

8-03-89

RECOVERY
PLAN

Effective
List
Effective
Date
Designation Date
Version
5-20-96
Final
4-16-10
Final
Proposed 9-16-08
60
4-12-01
Final
8-01-02
Final
10-16-06
Proposed 9-13-05

Federal
FT

FE

Date
2002

9-21-10

ST

CRITICAL
HABITAT

REPTILES
Desert tortoise
Gopherus agassizii

Draft
Revised

2008
1994

4-02-90

Final

2-08-94

FT
FE
FPE
FT
FT

7-28-78
10-13-70
3-16-10
7-28-78
7-28-78

Final

3-23-99

Final
Revised

Proposed

3-19-80

Revised

1998

Proposed

3-19-80

Revised

1998

FE

Green sea turtle
Chelonia mydas
Loggerhead sea turtle – North Pacific DPS64
Caretta caretta
Olive (=Pacific) Ridley sea turtle
Lepidochelys olivacea
Leatherback sea turtle
Dermochelys coriacea

FT

6-02-70

Proposed

1-05-10
3-23-99

Revised

1998

9-25-80

Final

1985

(Revised)

Final

1998

Barefoot banded gecko65
Coleonyx switaki
Coachella Valley fringe-toed lizard
Uma inornata
Blunt-nosed leopard lizard
Gambelia silus66
Flat-tailed horned lizard
Phrynosoma mcallii
Island night lizard
Xantusia riversiana

ST

10-02-80

SE

10-02-80

FT

9-25-80

SE

6-27-71

FE

3-11-67

Final

1998

6-28-06
11-29-93
8-11-77

Final

1984

Southern rubber boa
Charina bottae umbratica69

ST

Withdrawn
68

FPT
FT

67

Final

6-27-71

58

The Federal Circuit Court vacated critical habitat for the Arroyo toad on 10-30-02. The judge instructed the USFWS to begin the process of re-designating critical
habitat for this species. New critical habitat was first proposed on 4-27-04 and proposed with revisions on 2-14-05. A new final rule became effective 5-13-05.
59
Current taxonomy: Rana draytoni
60
Proposed rule is for revised Critical Habitat boundaries
61
Federal listing refers to the distinct population segment (DPS) in the San Gabriel, San Jacinto & San Bernardino Mountains only.
62
The current common name for this species is Sierra Madre yellow-legged frog.
63
The Fish and Game Commission notice of finding states that the mountain yellow-legged frog, Rana muscosa and Rana sierrae are candidates for listing as either
endangered or threatened species.
64
1978 listing was for the worldwide range of the species. The Mar 16, 2010 proposed rule is for the north pacific DPS (north of the equator & south of 60 degrees north
latitude).
65
Current nomenclature: Barefoot gecko.
66
Current taxonomy: Gambelia sila.is the scientific name and bluntnose leopard lizard is the common name
67
On June 28, 2006 the USFWS determined that the posposed listing was not warranted and the proposed rule that had been reinstated on Nov 17, 2005 was withdrawn.
68
On November 17, 2005, the U. S. District Court for the District of Arizona vacated the January 3, 2003 withdrawal of the proposed rule to list the flat-tailed horned
lizard and reinstated the 1993 proposed rule.
69
Current taxonomy: Charina umbratica.

8

January 2011

00004070
Endangered and Threatened Animals of California

LISTING STATUS

State
Alameda whipsnake
Masticophis lateralis euryxanthus

List
Date

ST

6-27-71

CRITICAL
HABITAT

Federal

Effective
List
Date
Designation

FT

12-05-97

Final
Proposed
70

Vacated71

Final
San Francisco garter snake
Thamnophis sirtalis tetrataenia
Giant garter snake
Thamnophis couchi gigas72

RECOVERY
PLAN
Effective
Date
Version
11-01-06
10-18-05

Date

Draft

2003

5-09-03
10-03-00

SE

6-27-71

FE

3-11-67

Final

1985

ST

6-27-71

FT

10-20-93

Draft

1999

FE

8-30-00

Final

2009

6-03-09
6-27-71

delisted
FE

12-17-09
2-20-08
10-13-70
3-20-01
12-12-90
3-11-67
3-11-67

Final

1983

Final

1991

Revised

1996

Final

1982

Final

1982

BIRDS
Short-tailed albatross
Phoebastria albatrus
California brown pelican73 (Recovered)
Pelecanus occidentalis californicus

delisted

SE

Aleutian Canada goose (Recovered)
Branta canadensis leucopareia74
California condor
Gymnogyps californianus

SE

6-27-71

delisted
FT
FE
FE

Bald eagle
Haliaeetus leucocephalus

SE(rev)
SE

10-02-80
6-27-71

delisted75
FT
FE(rev)

FE
Swainson’s hawk
Buteo swainsoni
American peregrine falcon (Recovered)
Falco peregrinus anatum

ST

4-17-83
11-04-09
6-27-71

Arctic peregrine falcon (Recovered)
Falco peregrinus tundrius
California black rail
Laterallus jamaicensis coturniculus
California clapper rail
Rallus longirostris obsoletus
Light-footed clapper rail
Rallus longirostris levipes
Yuma clapper rail
Rallus longirostris yumanensis

70
71
72
73
74
75

9-22-77

8-08-07
7-06-99
8-11-95
2-14-78
3-11-67

delisted
FE

8-25-99
6-02-70

delisted
FT
FE

delisted
SE

Final

Final

9-22-77

10-05-94
3-20-84
6-02-70

ST

6-27-71

SE

6-27-71

FE

10-13-70

Final

1984

SE

6-27-71

FE

10-13-70

ST
SE

2-22-78
6-27-71

FE

3-11-67

Revised
Final
Final

1985
1979
1983

The proposed rule redesignates Critical Habitat that was vacated in 2003.
Due to legal action on 9 May 2003, the Critical Habitat designation has been completely vacated; there is currently no Critical Habitat for Alameda whipsnake.
Current taxonomy and Federal listing: Thamnophis gigas.
Federal: Brown pelican, Pelecanus occidentalis.
Current taxonomy: Branta hutchinsii leucopareia, and common name is now cackling goose.
The Post-delisting Monitoring Plan will monitor the status of the bald eagle over a 20 year period with sampling events held once every 5 years.

9

January 2011

00004071
Endangered and Threatened Animals of California

LISTING STATUS

Greater sandhill crane
Grus Canadensis tabida

CRITICAL
HABITAT

Western snowy plover76
Charadrius alexandrinus nivosus

Federal

Effective
List
Date
Designation

FT

State
ST

List
Date
4-17-83

4-05-93

Final
Proposed

Final
78

Mountain plover
Charadrius montanus
California least tern
Sterna antillarum browni79
Marbled murrelet
Brachyramphus marmoratus80
Xantus’s murrelet
Synthliboramphus hypoleucus
Western yellow-billed cuckoo
Coccyzus americanus occidentalis
Elf owl
Micrathene whitneyi
Northern spotted owl
Strix occidentalis caurina

FPT

Bank swallow
Riparia riparia
Coastal California gnatcatcher
Polioptila californica californica

Effective
Date
Version
Draft
(state)
10-31-05
8-16-05
12-07-9977

Date

Final
Draft

2007
2001

Revised
Final
Final

1985
1980
1997

6-29-10

SE

6-27-71

FE

10-13-70

SE

3-12-92

FT

9-30-92

Proposed
81

7-31-08

Final
82

ST

SE
ST

Final

9-12-08
6-17-07
1-15-92

Final
Draft

2008
2007

11-18-05
10-12-04
7-22-97

Final

2002

Final
(state)
Exempt

1993

3-26-88
6-27-71

SE

5-24-96

12-22-04

10-02-80
FT

6-22-90

Proposed

Final
Great gray owl
Strix nebulosa
Gila woodpecker
Melanerpes uropygialis
Gilded northern flicker83
Colaptes auratus chrysoides
Willow flycatcher
Empidonax traillii
Southwestern willow flycatcher
Empidonax traillii extimus

RECOVERY
PLAN

SE

10-02-80

SE

3-17-88

SE

3-17-88

SE84

1-02-91

(SE)

FE

3-29-95

Final
Proposed

Final85
ST

6-11-89
FT

3-30-93

Final
Proposed
86

Final

1-18-08
4-24-03
10-24-00

76

Federal status applies only to the Pacific coastal population.
The Dec 7, 1999 designation was remanded & partially vacated by the US District Court for the District of Oregon on July 2, 2003.
78
The Jun 29, 2010 proposed rule reinstates that portion of the Dec 5, 2002 proposed rule concerning the listing of the plover as threatened. It doesn’t reinstate the
portion of the rule regarding a special rule under section 4(d) of the ESA.
79
Current taxonomy is Sternula antillarum browni
80
Federal: Brachyramphus marmoratus marmoratus with a proposal (7-31-08) to change the name to Brachyramphus marmoratus.
81
Proposed rule to revise the previously designated Critical Habitat.
82
The Fish and Game Commission determined that Xantus’s murrelet should be listed as a Threatened species February 24, 2004. As part of the normal listing process,
this decision was reviewed by the Office of Administrative Law. The listing became effective on Dec 22, 2004.
83
Current taxonomy: Gilded flicker (Colaptes chrysoides).
84
State listing includes all subspecies.
85
On May 11, 2001 the 10th Circuit Court of Appeals vacated the previously designated Critical Habitat
86
Due to court order the previously designated critical habitat was vacated and the USFWS was directed to re-propose critical habitat.
77

10

January 2011

00004072
Endangered and Threatened Animals of California

LISTING STATUS

RECOVERY
PLAN

Federal
FE

Effective
List
Date
Designation
8-11-77

10-02-80

FE

5-02-86

Final

2-02-94

Draft

1998

10-02-80

FT

8-03-87

Final

8-03-87

Final

1998

FT

8-11-77

Final

1984

delisted
FE

10-12-83
6-04-73

FE89

4-05-02

Final

1998

State
San Clemente loggerhead shrike
Lanius ludovicianus mearnsi
Arizona Bell’s vireo
Vireo bellii arizonae
Least Bell’s vireo
Vireo bellii pusillus
Inyo California towhee87 88
Pipilo crissalis eremophilus
San Clemente sage sparrow
Amphispiza belli clementeae
Belding’s savannah sparrow
Passerculus sandwichensis beldingi
Santa Barbara song sparrow (Extinct)
Melospiza melodia graminea

CRITICAL
HABITAT

List
Date

SE

3-17-88

SE
SE

SE

Effective
Date
Version
Final

Date
1984

1-10-74

MAMMALS
Buena Vista Lake shrew
Sorex ornatus relictus
Lesser long-nosed bat
Leptonycteris yerbabuenae
Riparian brush rabbit
Sylvilagus bachmani riparius
Point Arena mountain beaver
Aplodontia rufa nigra
San Joaquin antelope squirrel90
Ammospermophilus nelsoni
Mohave ground squirrel91
Spermophilus mohavensis
Pacific pocket mouse
Perognathus longimembris pacificus
Morro Bay kangaroo rat
Dipodomys heermanni morroensis
Giant kangaroo rat
Dipodomys ingens
Stephens’ kangaroo rat
Dipodomys stephensi92
San Bernardino kangaroo rat
Dipodomys merriami parvus
Tipton kangaroo rat
Dipodomys nitratoides nitratoides
Fresno kangaroo rat
Dipodomys nitratoides exilis

87
88
89
90
91
92
93
94

Final
Proposed

2-23-05
8-19-04

FE

ST

FE

3-24-00

Final

1998

12-12-91

Final

1998

9-26-94

Final

1998

Draft
revision

2000

Final
Final

1982
1998

Final

1998

Final

1998

10-02-80

ST

1997

FE

5-29-94

Final

FE

SE

10-31-88

6-27-71

SE

6-27-71

FE

10-13-70

SE

10-02-80

FE

1-05-87

ST

6-27-71

FE

9-30-88

FE93

9-24-98

SE

6-11-89

FE

10-02-80
6-27-71

FE

3-01-85

Final94
Final

8-11-77

11-17-08
5-23-02

7-08-88

SE
SR

Final

Final

1-30-85

Federal: Inyo California (=brown) towhee.
Current taxonomy is Melozone crissalis eremophilus
Federal: Buena Vista Lake ornate shrew
Current taxonomy: Nelson’s antelope squirrel
Current taxonomy: Xerospermophilus mohavensis
Federal: includes Dipodomys cascus.
Federal: San Bernardino Merriam’s kangaroo rat
This final revised designation constitutes a reduction of approximately 25,516 acres from the 2002 designation of Critical Habitat.

11

January 2011

00004073
Endangered and Threatened Animals of California

LISTING STATUS

Salt-marsh harvest mouse
Reithrodontomys raviventris
Amargosa vole
Microtus californicus scirpensis
Riparian woodrat
Neotoma fuscipes riparia
Sierra Nevada red fox
Vulpes vulpes necator
San Joaquin kit fox
Vulpes macrotis mutica
Island fox
Urocyon littoralis
San Miguel Island Fox
Urocyon littoralis littoralis

CRITICAL
HABITAT

State
SE

List
Date
6-27-71

Federal
FE

Effective
List
Date
Designation
10-13-70

SE

10-02-80

FE

11-15-84

FE95

Effective
Date
Version
Final

6-27-71

ST96

Final

1997

3-24-00

Final

1998

FE

3-11-67

Final

1998

4-05-04

Draft

2007

10-02-80

ST

11-15-84

6-27-71

(ST)

Final97
(none)

12-09-05

Proposed

10-07-04

98

Santa Rosa Island Fox
Urocyon littoralis santarosa

Date
1984

FE

ST

Final

RECOVERY
PLAN

(ST)

FE

4-05-04

Final 97
(none)

12-09-05

Proposed

10-07-04

98

Santa Cruz Island Fox
Urocyon littoralis santacruzae

(ST)

FE

4-05-04

Final 97
(none)

12-09-05

Proposed

10-07-04

98

Santa Catalina Island Fox
Urocyon littoralis catalinae

(ST)

FE

4-05-04

Final 97
(none)

12-09-05

Proposed

10-07-04

98

Guadalupe fur seal
Arctocephalus townsendi
Stellar (=northern) sea lion
Eumetopias jubatus
Wolverine
Gulo gulo
Southern sea otter
Enhydra lutris nereis
Pacific fisher
Martes pennanti(pacifica) DPS

ST

6-27-71

FT
FE

1-15-86
3-11-67

FT

4-05-90

(revised)

Final

3-23-99

Revised

Final
ST

2008
1992

Revised
Final

2003
1981

6-27-71
FT

1-14-77

Gray whale (Recovered)
Eschrichtius robustus

delisted

FE

6-15-94
6-02-70

Sei whale
Balaenoptera borealis

FE

6-02-70

SCT
or
SCE99

Listing
Not
warranted

95

Federal: Riparian (=San Joaquin Valley) woodrat
State listing includes all 6 subspecies on all 6 islands. Federal listing is for only 4 subspecies on 4 islands
97
The USFWS did not find any habitat on the 4 islands occupied by the foxes that meets the definition of Critical Habitat under the Act. Therefore, the final rule does not
designate any Critical Habitat
98
The USFWS did not find any habitat on the 4 islands occupied by the foxes that meets the definition of Critical Habitat under the Act. Therefore, the proposal is that
zero Critical Habitat be designated.
99
The Fish and Game Commission notice of finding states that the Pacific fisher is a candidate for listing as either an endangered or a threatened species. At the June 23,
2010 meeting the Commission determined that the listing was not warranted.
96

12

January 2011

00004074
Endangered and Threatened Animals of California

LISTING STATUS

CRITICAL
HABITAT

RECOVERY
PLAN

6-02-70

Draft

2006

FE

6-02-70

Final

1991

FE

6-02-70

Final

1991

FE

6-02-70

Draft

2006

FE103
FE

Blue whale
Balaenoptera musculus
Fin whale
Balaenoptera physalus
Humpback whale100
Megaptera novaeangliae
Right whale101
Eubalaena japonica102
Sperm whale
Physeter macrocephalus
Killer whale (Southern resident DPS)
Orcinus orca

Federal
FE

Effective
List
Date
Designation
6-02-70

FE

State

List
Date

4-04-07
2-16-06
12-22-04

Final

2008

1-03-00

9-04-08
7-25-07

Final
Draft

2008
2003

5-14-09
10-10-07

Final

2000

California (=Sierra Nevada) bighorn sheep
Ovis canadensis californiana104

SE
ST

8-27-99
6-27-71

FE

Peninsular bighorn sheep DPS105
Ovis canadensis cremnobates

ST

6-27-71

FE

Final
Proposed

3-18-98

Final
Proposed
(Revised)

Final

Effective
Date
Version
Final

Date
1998

3-05-01

100

Also known as Hump-backed whale.
Also known as Black right whale.
102
The scientific name was clarified in the Federal Register Vol. 68, No. 69 April 10, 2003.
103
The killer whale was listed as endangered by the NMFS on Feb 16, 2006 and by the USFWS on Apr 4, 2007.
104
Current & Federal taxonomy: Sierra Nevada bighorn sheep (Ovis canadensis sierrae)
105
Current taxonomy: the subspecies O.c. cremnobates has been synonymized with O.c. nelsoni. Peninsular bighorn sheep are now considered to be a Distinct
Vertebrate Population Segment (DPS).
101

13

January 2011

00004075
State of California
The Resources Agency
DEPARTMENT OF FISH AND GAME
Resource Management and Planning Division
Biogeographic Data Branch
California Natural Diversity Database
STATE AND FEDERALLY LISTED
ENDANGERED, THREATENED, AND RARE PLANTS OF CALIFORNIA
October 2012
Designations and Subtotals for each Designation:
Designations:
SE
ST
SR
SC
FE
FT
FPE
FPT

Subtotals:

State-listed endangered
State-listed threatened
State-listed rare
State candidate for listing
Federally listed endangered
Federally listed threatened
Federally proposed endangered
Federally proposed threatened
Both State and Federally listed

134
22
64
0
139
47
0
0
125

State listing is pursuant to §1904 (Native Plant Protection Act of 1977) and §2074.2 and §2075.5 (California
Endangered Species Act of 1984) of the Fish and Game Code, relating to listing of Endangered, Threatened
and Rare species of plants and animals. Federal listing is pursuant with the Federal Endangered Species Act
of 1973, as amended. For information regarding plant conservation, contact the Habitat Conservation
Planning Branch, 1416 Ninth Street, Sacramento, CA 95814, phone [phone], or the nearest
Department of Fish and Game office. For information on this list, contact CNDDB’s Information Services
at [phone]. Scientific and common names for State-listed plants are listed in Title 14, §670.2.
Scientific or common names in parentheses are the most scientifically accepted nomenclature but have yet to
be officially adopted into the California Code of Regulations, Title 14, Division 1, §670.2.
State Designated Plants
Acanthomintha duttonii
San Mateo thorn-mint
Acanthomintha ilicifolia
San Diego thorn-mint
Agrostis blasdalei var. marinensis (=Agrostis blasdalei)
Marin bent grass
Allium munzii
Munz's onion
Allium yosemitense
Yosemite onion

Classification
State List Date
SE
Jul 1979
SE

Jan 1982

Federal
FE

List Date
Sep 18,1985

FT

Oct 13,1998

FE

Oct 13,1998

Delisted
April 2008.

ST

Jan 1990

SR

Jul 1982

00004076
State Designated Plants

Classification
State List Date

SR

FE

Sep 28,1978

Jul 31,1997

Oct 07,1996

FE

Oct 26,1979

Dec 15,1994

FT

Jul 1979

Jul 31,1997

FT

Arctostaphylos confertiflora
Santa Rosa Island manzanita
Arctostaphylos densiflora
Vine Hill manzanita
Arctostaphylos edmundsii var. parvifolia
Hanging Gardens manzanita

SE

May 08,1985

FE

Baker's manzanita

Apr 1982

FE
FE

SE

July 2, 2002

FE

Amsinckia grandiflora
large-flowered fiddleneck
Arabis hoffmannii
Hoffmann's rock cress
Arabis macdonaldiana
McDonald's rock cress
Arctostaphylos bakeri (=A. b. ssp. bakeri and A. b. ssp. sublaevis)

List Date
Oct 22,1997

FE

Alopecurus aequalis var. sonomensis
Sonoma alopecurus
Ambrosia pumila
San Diego ambrosia

Federal
FE

May 26,1999

Sep 1979

SE

Aug 1981
Delisted
April 2008

Arctostaphylos glandulosa ssp. crassifolia
Del Mar manzanita
Arctostaphylos hookeri ssp. hearstiorum
Hearst's manzanita

SE

Sep 1979

Arctostaphylos hookeri ssp. ravenii
Presidio manzanita
Arctostaphylos imbricata
San Bruno Mountain manzanita
Arctostaphylos morroensis
Morro manzanita

SE

Nov 1978

SE

Sep 1979

Arctostaphylos myrtifolia
Ione manzanita
Arctostaphylos pacifica
Pacific manzanita

SE

Sep 1979

Arctostaphylos pallida
pallid manzanita
Arenaria paludicola
marsh sandwort
Arenaria ursina
Big Bear Valley sandwort

SE

Nov 1979

FT

Apr 22,1998

SE

Feb 1990

FE

Aug 03,1993

FT

Sep 14,1998

Astragalus agnicidus
Humboldt milk-vetch

SE

FE

Aug 24,1994

Astragalus albens
Cushenbury milk-vetch
2

Apr 1982

00004077
State Designated Plants

Classification
State List Date

Oct 22,1997
Oct 06,1998

Oct 06,1998

FT

SR

Jan 1990

FE

FE

ST

List Date
Jan 29,1997

FE

Astragalus brauntonii
Braunton's milk-vetch
Astragalus claranus (= A. clarianus)
Clara Hunt's milk-vetch
Astragalus jaegerianus
Lane Mountain milk-vetch
Astragalus johannis-howellii
Long Valley milk-vetch
Astragalus lentiginosus var. coachellae
Coachella Valley milk-vetch
Astragalus lentiginosus var. piscinensis
Fish Slough milk-vetch
Astragalus lentiginosus var. sesquimetralis
Sodaville milk-vetch
Astragalus magdalenae var. peirsonii
Peirson's milk-vetch
Astragalus monoensis (= A. monoensis var. monoensis)
Mono milk-vetch
Astragalus pycnostachyus var. lanosissimus
Ventura Marsh milk-vetch
Astragalus tener var. titi
coastal dunes milk-vetch
Astragalus traskiae
Trask's milk-vetch
Astragalus tricarinatus
triple-ribbed milk-vetch
Atriplex coronata var. notatior
San Jacinto Valley crownscale
Atriplex tularensis
Bakersfield smallscale
Baccharis vanessae
Encinitas baccharis
Bensoniella oregona
bensoniella
Berberis nevinii
Nevin's barberry
Berberis pinnata ssp. insularis
island barberry
Blennosperma bakeri
Sonoma sunshine
Blennosperma nanum var. robustum
Point Reyes blennosperma

Federal
FE

Oct 06,1998

FT

Oct 06,1998

Jul 1982

SE

Sep 1979

SE

Nov 1979

SR

Jul 1982

SE

Apr 2000

FE

May 21,2001

SE

Feb 1982

FE

Aug 12,1998

SR

Nov 1979
FE

Oct 06,1998

FE

Oct 13,1998

FT

Oct 07,1996

SE
SE

Jul 1982

SE

Jan 1987

FE

Oct 13,1998

SE

Nov 1979

FE

Jul 31,1997

SE

Feb 1992

FE

Dec 02,1991

SR

Nov 1978

SR

Nov 1978

SE
3

Jan 1987

SR

Bloomeria humilis
dwarf goldenstar
Brodiaea coronaria ssp. rosea
Indian Valley brodiaea

Jan 1987

Sep 1979

00004078
State Designated Plants

Classification
State List Date
SE
Jan 1982
SE
SE

Nov 1978

Calamagrostis foliosa
leafy reed grass

SR
SR
SR
ST

May 1987

Sep 14,1998

FE

Oct 18,1996
Feb 12,1985

FE

Oct 22,1997

Jul 1982

Calochortus tiburonensis
Tiburon mariposa lily

Feb 03,1995

Nov 1979

Calochortus persistens
Siskiyou mariposa lily

FT

Nov 1979

Calochortus dunnii
Dunn's mariposa lily

Sep 14,1998

Nov 1979

Brodiaea pallida
Chinese Camp brodiaea

FT

FT

Brodiaea insignis
Kaweah brodiaea

List Date
Oct 13,1998

FT

Brodiaea filifolia
thread-leaved brodiaea

Federal
FT

Calyptridium pulchellum
Mariposa pussypaws
Calystegia stebbinsii
Stebbins's morning-glory

SE

Aug 1981

Camissonia benitensis
San Benito evening-primrose
Carex albida
white sedge

SE

Nov 1979

Carex tompkinsii
Tompkins's sedge

SR

Nov 1979

Carpenteria californica
tree-anemone

ST

Jan 1990

Castilleja affinis ssp. neglecta
Tiburon Indian paintbrush

ST

Jan 1990

FE

Feb 03, 1995

Castilleja campestris ssp. succulenta
succulent owl's-clover

SE

Sep 1979

FT

Mar 26,1997

FT

Sep 14,1998

FE

Aug 11,1977

Castilleja cinerea
ash-gray Indian paintbrush
Castilleja gleasonii
Mt. Gleason Indian paintbrush

SR

Jul 1982

Castilleja grisea
San Clemente Island Indian paintbrush

SE

Apr 1982

4

00004079
State Designated Plants

Classification
State List Date

Castilleja uliginosa
Pitkin Marsh Indian paintbrush

SE
SE

Jan 1987

FE

Jul 19,1990

Feb 03,1995

Nov 1978

Caulanthus californicus
California jewel-flower

List Date
Jul 31,1997

FE

Castilleja mollis
soft-leaved Indian paintbrush

Federal
FE

Caulanthus stenocarpus
slender-pod jewel-flower

Delisted
April 2008

Ceanothus ferrisae
coyote ceanothus
Ceanothus hearstiorum
Hearst's ceanothus

SR

Aug 1981

Ceanothus maritimus
maritime ceanothus

SR

Nov 1978

Ceanothus masonii
Mason's ceanothus

SR

Nov 1978

Ceanothus ophiochilus
Vail Lake ceanothus

SE

Jan 1994

FT

Oct 13,1998

Ceanothus roderickii
Pine Hill ceanothus

SR

Jul 1982

FE

Oct 18,1996

Cercocarpus traskiae
Catalina Island mountain-mahogany

SE

Apr 1982

FE

Aug 08,1997

Chamaesyce hooveri
Hoover's spurge

FT

Mar 26,1997

Chlorogalum purpureum var. purpureum1
purple amole

FT

Mar 20,2000

Chlorogalum purpureum var. reductum2
Camatta Canyon amole

SR

Nov 1978

FT

Mar 20,2000

Chorizanthe howellii
Howell's spineflower

ST

Jan 1987

FE

Jun 22,1992

Chorizanthe orcuttiana
Orcutt's spineflower

SE

Nov 1979

FE

Oct 07,1996

1
2

The U.S. Fish & Wildlife Service listed the entire species, Chlorogalum purpureum.
The U.S. Fish & Wildlife Service listed the entire species, Chlorogalum purpureum.

5

00004080
State Designated Plants

Classification
State List Date
SE
Aug 2001

Chorizanthe parryi var. fernandina
San Fernando Valley spineflower

Federal

List Date

Chorizanthe pungens var. hartwegiana
Ben Lomond spineflower

FE

Feb 04,1994

Chorizanthe pungens var. pungens
Monterey spineflower

FT

Feb 04,1994

Chorizanthe robusta (includes vars. hartwegii and robusta)
robust spineflower
Chorizanthe valida
Sonoma spineflower

FE

Feb 04,1994

FE

Jun 22,1992

SE

Jan 1990

Cirsium ciliolatum
Ashland thistle
Cirsium fontinale var. fontinale
fountain thistle

SE

Sep 1982

SE

Jul 1979

FE

Feb 03,1995

Cirsium fontinale var. obispoense
Chorro Creek bog thistle

SE

Jun 1993

FE

Dec 15,1994

FE

Nov 20,1997

FE

Mar 20,2000

Cirsium hydrophilum var. hydrophilum
Suisun thistle
Cirsium loncholepis
La Graciosa thistle

ST

Feb 1990

Cirsium rhothophilum
surf thistle

ST

Feb 1990

Clarkia franciscana
Presidio clarkia

SE

Nov 1978

FE

Feb 03,1995

Clarkia imbricata
Vine Hill clarkia

SE

Nov 1978

FE

Oct 22,1997

Clarkia lingulata
Merced clarkia

SE

Jan 1989

Clarkia speciosa ssp. immaculata
Pismo clarkia

SR

Nov 1978

FE

Dec 15,1994

Clarkia springvillensis
Springville clarkia

SE

Sep 1979

FT

Sep 14,1998

Cordylanthus maritimus ssp. maritimus
salt marsh bird's-beak

SE

Jul 1979

FE

Sep 28,1978

Cordylanthus mollis ssp. mollis
soft bird's-beak

SR

Jul 1979

FE

Nov 20,1997

Cordylanthus nidularius
Mt. Diablo bird's-beak

SR

Nov 1978

Cordylanthus palmatus
palmate-bracted bird's-beak

SE

May 1984

FE

Jul 01, 1986

Cordylanthus rigidus ssp. littoralis
seaside bird's-beak

SE

Jan 1982

6

00004081
State Designated Plants

Classification
State List Date
SR
Nov 1978

Cordylanthus tenuis ssp. capillaris
Pennell's bird's-beak

SR
SR
SE

Nov 1979

Jan 08,1987
Aug 12,1998

Jul 1982

Cupressus abramsiana (= Callitropsis abramsiana)
Santa Cruz cypress

FE

Jan 1982

Cryptantha roosiorum
bristlecone cryptantha

List Date
Feb 03,1995

FT

Croton wigginsii
Wiggins’ croton

Federal
FE

Cupressus goveniana ssp. goveniana (=Callitropsis goveniana)
Gowen cypress
Dedeckera eurekensis
July gold

SR

Nov 1978

Deinandra arida (=Hemizonia arida)
Red Rock tarplant

SR

Jul 1982

Deinandra conjugens (=Hemizonia conjugens)
Otay tarplant

SE

Nov 1979

FT

Oct 13,1998

Deinandra increscens ssp. villosa(=Hemizonia increscens ssp. villosa)
Gaviota tarplant

SE

Jan 1990

FE

Mar 20,2000

Deinandra minthornii (= Hemizonia minthornii)
Santa Susana tarplant

SR

Nov 1978

Deinandra mohavensis (= Hemizonia mohavensis)
Mojave tarplant

SE

Aug 1981

Delphinium bakeri
Baker's larkspur

SE

April 2007

FE

Jan 26,2000

Delphinium hesperium ssp. cuyamacae
Cuyamaca larkspur

SR

Jul 1982

Delphinium luteum
yellow larkspur

SR

Sep 1979

FE

Jan 26,2000

Delphinium variegatum ssp. kinkiense
San Clemente Island larkspur

SE

Sep 1979

FE

Aug 11,1977

Dichanthelium lanuginosum var. thermale
Geysers dichanthelium

SE

Sep 1978

Dieteria asteroides var. lagunensis

SR

Sep 1979

Dithyrea maritima
beach spectaclepod

ST

Feb 1990

Dodecahema leptoceras
slender-horned spineflower

SE

Jan 1982

FE

Sep 28,1987

Downingia concolor var. brevior
Cuyamaca Lake downingia

SE

Feb 1982

Mount Laguna aster (= Machaeranthera asteroides var. lagunensis)

7

00004082
State Designated Plants

Classification
State List Date

SR

Nov 1978

Dudleya cymosa ssp. ovatifolia
Santa Monica Mountains dudleya
Dudleya nesiotica
Santa Cruz Island dudleya

SR

Jan 29,1997
Jan 29,1997

FT

Jul 31,1997
Feb 03,1995

Jan 1982

Dudleya cymosa ssp. agourensis 3
Santa Monica Mtns. dudleya
Dudleya cymosa ssp. marcescens
marcescent dudleya

FT

FE

SE

Jan 29, 1997

FT

Dudleya brevifolia (=D. blochmaniae ssp. brevifolia)
short-leaved dudleya

List Date
Jan 29,1997

FT

Dudleya abramsii ssp. parva (=D. parva)
Conejo dudleya

Federal
FT

Nov 1979

Dudleya setchellii
Santa Clara Valley dudleya
Dudleya stolonifera
Laguna Beach dudleya

ST

Jan 1987

FT

Oct 13,1998

Dudleya traskiae
Santa Barbara Island dudleya

SE

Nov 1979

FE

Apr 26,1978

Dudleya verityi
Verity's dudleya

FT

Jan 29,1997

Enceliopsis nudicaulis var. corrugata
Ash Meadows daisy

FT

May 20,1985

Eremalche kernensis
Kern mallow

FE

Jul 19,1990

FE

Sep 28,1987

Delisted

Oct 7,2003

Eriastrum densifolium ssp. sanctorum
Santa Ana River woollystar

SE

Jan 1987

Eriastrum hooveri
Hoover's woolly-star
Eriastrum tracyi
Tracy's eriastrum

SR

Jul 1982

Erigeron parishii
Parish's daisy

FT

Aug 24,1994

Eriodictyon altissimum
Indian Knob mountainbalm

Jul 1979

FE

Dec 15,1994

Eriodictyon capitatum
Lompoc yerba santa
3

SE
SR

Sep 1979

FE

Mar 20,2000

The U.S. Fish & Wildlife Service has listed the more encompassing Dudleya cymosa ssp. ovatifolia from which ssp. agourensis
was split.

8

00004083
State Designated Plants

Classification
State List Date
SE
Jul 1979

Eriogonum alpinum
Trinity buckwheat

Federal

List Date

Eriogonum apricum var. apricum4
Ione buckwheat

SE

Aug 1981

FE

May 26,1999

Eriogonum apricum var. prostratum5
Irish Hill buckwheat

SE

Jan 1987

FE

May 26,1999

Eriogonum butterworthianum
Butterworth's buckwheat

SR

Nov 1979

Eriogonum crocatum
Conejo buckwheat

SR

Sep 1979

Eriogonum giganteum var. compactum
Santa Barbara Island buckwheat

SR

Nov 1979

Eriogonum grande ssp. timorum (= Eriogonum grande var. timorum)
San Nicolas Island buckwheat

SE

Nov 1979

SE

Apr 1982

Eriogonum kennedyi var. austromontanum
southern mountain buckwheat

FT

Sep 14,1978

Eriogonum ovalifolium var. vineum
Cushenbury buckwheat

FE

Aug 24,1994

Eriogonum kelloggii
Kellogg's buckwheat

Eriogonum thornei (= E. ericifolium var. thornei)
Thorne's buckwheat

SR

Jul 1982

Eriophyllum congdonii
Congdon's woolly sunflower

SR

Jul 1982

Eriophyllum latilobum
San Mateo woolly sunflower

SE

Jun 1992

FE

Feb 03,1995

Eryngium aristulatum var. parishii
San Diego button-celery

SE

Jul 1979

FE

Aug 03,1993

Eryngium constancei
Loch Lomond button-celery

SE

Jan 1987

FE

Dec 23,1986

Eryngium racemosum
Delta button-celery

SE

Aug 1981

Erysimum capitatum var. angustatum
Contra Costa wallflower

5

Nov 1979

Eriogonum twisselmannii
Twisselmann's buckwheat

4

SE

SE

Nov 1978

FE

Apr 26,1978

The U.S. Fish & Wildlife Service has listed Eriogonum apricum as the species, which includes both rare varieties.
The U.S. Fish & Wildlife Service has listed Eriogonum apricum as the species, which includes both rare varieties.

9

00004084
State Designated Plants

Classification
State List Date
SE
Sep 1984

6

Erysimum menziesii
Menzies’ wallflower

Federal
FE

List Date
Jun 22,1992

Erysimum teretifolium
Santa Cruz wallflower

SE

Aug 1981

FE

Feb 04,1994

Fremontodendron decumbens
Pine Hill flannelbush

SR

Jul 1979

FE

Oct 18,1996

Fremontodendron mexicanum
Mexican flannelbush

SR

Jul 1982

FE

Oct 13,1998

FE

Dec 10,1999

Fritillaria gentneri
Gentner’s fritillary
Fritillaria roderickii
Roderick's fritillary

SE

Nov 1979

Fritillaria striata
striped adobe-lily

ST

Jan 1987

Galium angustifolium ssp. borregoense
Borrego bedstraw

SR

Sep 1979

Galium buxifolium
box bedstraw

SR

Nov 1979

FE

Jul 31,1997

Galium californicum ssp. sierrae
El Dorado bedstraw

SR

Nov 1979

FE

Oct 18,1996

Galium catalinense ssp. acrispum
San Clemente Island bedstraw

SE

Apr 1982

Gilia tenuiflora ssp. arenaria
sand gilia

ST

Jan 1987

FE

Jun 22,1992

FE

Jul 31,1997

FT

May 20,1985

FT

Jul 31,1997

FT

Feb 03,1995

Gilia tenuiflora ssp. hoffmannii
Hoffmann’s slender-flowered gilia
Gratiola heterosepala
Boggs Lake hedge-hyssop
Grindelia fraxino-pratensis
Ash Meadows gumplant

SE

Hazardia orcuttii
Orcutt’s hazardia

ST

Nov 1978

Aug 2002

Helianthemum greenei
island rush-rose
Helianthus niveus ssp. tephrodes
Algodones Dunes sunflower

Nov 1979

Hesperolinon congestum
Marin western flax

6

SE
ST

Jun 1992

The U.S. Fish & Wildlife Service separately listed all as endangered, E. menziesii ssp. eurekense, E. menziesii ssp. menziesii, and
E. menziesii ssp. yadonii.

10

00004085
State Designated Plants

Classification
State List Date
SE
Aug 1981

Hesperolinon didymocarpum
Lake County western flax
Holmgrenanthe petrophila (= Maurandya petrophila)
rock lady

SR
SE

Sep 1979

List Date

Jul 1982

Holocarpha macradenia
Santa Cruz tarplant

Federal

FT

Mar 20,2000

FT

Jul 14,1994

FE

Dec 02,1991

FE

Jun 18,1997

FE

Jun 22,1992

Lembertia congdonii (=Monolopia congdonii)
San Joaquin woollythreads

FE

Jul 19,1990

Lesquerella kingii ssp. bernardina
San Bernardino Mountains bladderpod

FE

Aug 24,1994

FE

Jun 19,1997

Howellia aquatilis
water howellia
Ivesia callida
Tahquitz ivesia

SR

Jul 1982

Lasthenia burkei
Burke's goldfields

SE

Sep 1979

Lasthenia conjugens
Contra Costa goldfields
Layia carnosa
beach layia

SE

Jan 1990

Lessingia germanorum
San Francisco lessingia

SE

Jan 1990

Lewisia congdonii
Congdon's lewisia

SR

Jul 1982

Lilaeopsis masonii
Mason's lilaeopsis

SR

Nov 1979

Lilium occidentale
western lily

SE

Jan 1982

FE

Aug 17,1994

Lilium pardalinum ssp. pitkinense
Pitkin Marsh lily

SE

Nov 1978

FE

Oct 22,1997

Limnanthes bakeri
Baker's meadowfoam

SR

Nov 1978

Limnanthes douglasii var. sulphurea (=Limnanthes douglasii ssp.
sulphurea)
Point Reyes meadowfoam
Limnanthes floccosa ssp. californica
Butte County meadowfoam

SE

Apr 1982

SE

Feb 1982

FE

Jun 08,1992

Limnanthes gracilis var. parishii (=Limnanthes gracilis ssp. parishii)
Parish’s meadowfoam

SE

Jul 1979

Limnanthes vinculans
Sebastopol meadowfoam

SE

Nov 1979

FE

Dec 02,1991

11

00004086
State Designated Plants

Classification
State List Date
SE
Feb 1982

Lithophragma maximum
San Clemente Island woodland star

Federal
FE

List Date
Aug 08,1997

FE

Aug 11,1977

FE

Mar 20,2000

Lotus argophyllus var. adsurgens
San Clemente Island bird's-foot trefoil

SE

Nov 1979

Lotus argophyllus var. niveus
Santa Cruz Island bird's-foot trefoil

SE

Aug 1981

Lotus dendroideus var. traskiae
San Clemente Island lotus

SE

Apr 1982

Lupinus citrinus var. deflexus
Mariposa lupine

ST

Jan 1990

Lupinus milo-bakeri
Milo Baker's lupine

ST

Jan 1987

Lupinus nipomensis
Nipomo Mesa lupine

SE

Jan 1987

Lupinus padre-crowleyi
Father Crowley's lupine

SR

Aug 1981

Lupinus tidestromii var. tidestromii (=L. tidestromii)
Tidestrom's lupine

SE

Jan 1987

FE

Jun 22,1992

Delisted
April 2008

Delisted

Oct 1,2003

Machaeranthera lagunensis
(see Dieteria asteroides var. lagunensis)
Mahonia sonnei (= Berberis sonnei)
Truckee barberry
Malacothamnus clementinus
San Clemente Island bush mallow

SE

Feb 1982

FE

Aug 11,1977

Malacothamnus fasciculatus var. nesioticus
Santa Cruz Island bush mallow

SE

Nov 1979

FE

Jul 31,1997

Malacothrix indecora
Santa Cruz Island malacothrix

FE

Jul 31,1997

Malacothrix squalida
island malacothrix

FE

Jul 31,1997

Monardella linoides ssp. viminea (=M. viminea)
willowy monardella

SE

Nov 1979

FE

Oct 13,1998

Nasturtium gambellii (= Rorippa gambellii)
Gambel's water cress

ST

Feb 1990

FE

Aug 03,1993

FT

Oct 13,1998

FE

Jun 18,1997

Navarretia fossalis
spreading navarretia
Navarretia leucocephala ssp. pauciflora
few-flowered navarretia

ST

12

Jan 1990

00004087
State Designated Plants

Classification
State List Date
SE
Nov 1979

Navarretia leucocephala ssp. plieantha
many-flowered navarretia

Federal
FE

List Date
Jun 18,1997

Nemacladus twisselmannii
Twisselmann's nemacladus

SR

Jul 1982

Neostapfia colusana
Colusa grass

SE

Nov 1979

FT

Mar 26,1997

Nitrophila mohavensis
Amargosa nitrophila

SE

Nov 1979

FE

May 20,1985

Nolina interrata
Dehesa nolina
Oenothera californica ssp. eurekensis
Eureka Dunes evening-primrose

SE

Nov 1979

SR

Nov 1978

FE

Apr 26,1978

Oenothera deltoides ssp. howellii
Antioch Dunes evening-primrose
Opuntia basilaris var. treleasei
Bakersfield cactus
Orcuttia californica
California Orcutt grass

SE

Nov 1978

FE

Apr 26,1978

SE

Jan 1990

FE

Jul 19,1990

SE

Sep 1979

FE

Aug 03,1993

Orcuttia inaequalis
San Joaquin Valley Orcutt grass

SE

Sep 1979

FT

Mar 26,1997

Orcuttia pilosa
hairy Orcutt grass
Orcuttia tenuis
slender Orcutt grass

SE

Sep 1979

FE

Mar 26,1997

SE

Sep 1979

FT

Mar 26,1997

Orcuttia viscida
Sacramento Orcutt grass
Ornithostaphylos oppositifolia
Baja California birdbush

SE

Jul 1979

FE

Mar 26,1997

SE

Apr 2001
FE

Aug 24,1994

Oxytheca parishii var. goodmaniana (=Acanthoscyphus parishii
var. goodmaniana
Cushenbury oxytheca
Packera ganderi (= Senecio ganderi)
Gander’s ragwort
Packera layneae (= Senecio layneae)
Layne's ragwort
Parvisedum leiocarpum (=Sedella leiocarpa)
Lake County stonecrop
Pedicularis dudleyi
Dudley's lousewort
Pentachaeta bellidiflora
white-rayed pentachaeta
Pentachaeta lyonii
Lyon's pentachaeta
Phacelia insularis ssp. insularis
northern Channel Islands phacelia
13

SR

Jul 1982

SR

Nov 1979

FT

Oct 18,1996

SE

Jan 1990

FE

Jun 18,1997

SR

Sep 1979

SE

Jun 1992

FE

Feb 03,1995

SE

Jan 1990

FE

Jan 29,1997

FE

Jul 31,1997

00004088
State Designated Plants

Classification
State List Date
SE
Jan 1987

Phlox hirsuta
Yreka phlox
Piperia yadonii
Yadon's rein orchid
Plagiobothrys diffusus
San Francisco popcorn-flower
Plagiobothrys strictus
Calistoga popcorn-flower
Pleuropogon hooverianus
North Coast semaphore grass
Poa atropurpurea
San Bernardino blue grass
Poa napensis
Napa blue grass
Pogogyne abramsii
San Diego mesa mint
Pogogyne clareana
Santa Lucia mint
Pogogyne nudiuscula
Otay Mesa mint
Polygonum hickmanii
Scott’s Valley polygonum
Potentilla hickmanii
Hickman's cinquefoil
Pseudobahia bahiifolia
Hartweg's golden sunburst
Pseudobahia peirsonii
San Joaquin adobe sunburst
Rorippa subumbellata
Tahoe yellow cress
Rosa minutifolia
small-leaved rose
Sanicula maritima
adobe sanicle
Sanicula saxatilis
rock sanicle
Sedella leiocarpa (= Parvisedum leiocarpum)
Lake County stonecrop
Senecio ganderi
(see Packera ganderi)
Senecio layneae (=Packera layneae)

Federal
FE

List Date
Feb 3,2000

FE

Jan 1990

ST

Oct 22,1997

Sep 14,1998

Sep 1979

ST

FE

FE

SE

Aug 12,1998

Dec 2002

SE

FE

Oct 22,1997

SE

Jul 1979

FE

Sep 28,1978

SE

Nov 1979

SE

Jan 1987

FE

Aug 03,1993

SE

May 2005

FE

Apr 8,2003

SE

Sep 1979

FE

Aug 12,1998

SE

Aug 1981

FE

Feb 06,1997

SE

Jan 1987

FT

Feb 06,1997

SE

Apr 1982

SE

Oct 1989

SR

Aug 1981

SR

Jul 1982

SE

Jan 1990

FE

Jun 18,1997

FE

Sibara filifolia
Santa Cruz Island rock cress
Sidalcea covillei
Owens Valley checkerbloom

Jul 1979

Aug 08,1997

SE
14

Jul 1979

00004089
State Designated Plants

Classification
State List Date
SR
Nov 1979

Sidalcea hickmanii ssp. anomala
Cuesta Pass checkerbloom
Sidalcea hickmanii ssp. parishii
Parish's checkerbloom

SR

Nov 1979

Federal

List Date

Removed as
FC, 2006
Fed.
Register

FE

Sidalcea keckii
Keck’s checker-mallow
Sidalcea oregana ssp. valida
Kenwood Marsh checkerbloom
Sidalcea pedata
bird-foot checkerbloom
Sidalcea stipularis
Scadden Flat checkerbloom
Silene campanulata ssp. campanulata
Red Mountain catchfly
Streptanthus albidus ssp. albidus
Metcalf Canyon jewel-flower
Streptanthus niger
Tiburon jewel-flower
Suaeda californica
California seablite
Swallenia alexandrae
Eureka Valley dune grass
Taraxacum californicum
California dandelion
Thelypodium stenopetalum
slender-petaled thelypodium
Thermopsis macrophylla var. angina (=T. macrophylla)
Santa Ynez false lupine
Thlaspi californicum
Kneeland Prairie penny-cress
Thysanocarpus conchuliferus
Santa Cruz Island fringepod
Trichostema austromontanum ssp. compactum
Hidden Lake bluecurls
Trifolium amoenum
showy Indian clover
Trifolium polyodon
Pacific Grove clover
Trifolium trichocalyx
Monterey clover
Tuctoria greenei
Greene's tuctoria
Tuctoria mucronata
Crampton’s tuctoria
Verbena californica
California vervain

Feb 16,2000

SE

Jan 1982

FE

Oct 22,1997

SE

Jan 1982

FE

Aug 31,1984

SE

Jan 1982

SE

Apr 1982
FE

Feb 03,1995

FE

Feb 03,1995

FE

Dec 15,1994

FE

Apr 26,1978

FE

Sep 14,1998

FE

Aug 31,1984

FE

Feb 9,2000

FE

Jul 31,1997

FT

Sep 14,1998

FE

Oct 22,1997

SE

SR

Feb 1990

Aug 1981

SE

Feb 1982

SR

Aug 1981

SR
SE

Nov 1979

FE

Aug 12,1998

SR

Sep 1979

FE

Mar 26,1997

SE

Jul 1979

FE

Sep 28,1978

ST
15

Sep 1979

Aug 1994

FT

Sep 14,1998

00004090
State Designated Plants

Classification
State List Date
ST
Jan 1990

Verbesina dissita
Big-leaved crownbeard

16

Federal
FT

List Date
Oct 07,1996

00004091

00004092

APPENDIX D
AIR QUALITY CALCULATIONS

00004093

Water Truck
Diesel Road Compactors
Diesel Dump Truck
Diesel Excavator
Diesel Trenchers
Diesel Bore/Drill Rigs
Diesel Cement & Mortar Mixers
Diesel Cranes
Diesel Graders
Diesel Tractors/Loaders/Backhoes
Diesel Bull Dozers
Diesel Front End Loaders
Diesel Fork Lifts
Diesel Generator Set

Type of Construction Equipment

Emission Factors 1
VOC g/hp- CO g/hp- NOx g/hphr
hr
hr
0.440
2.070
5.490
0.370
1.480
4.900
0.440
2.070
5.490
0.340
1.300
4.600
0.510
2.440
5.810
0.600
2.290
7.150
0.610
2.320
7.280
0.440
1.300
5.720
0.350
1.360
4.730
1.850
8.210
7.220
0.360
1.380
4.760
0.380
1.550
5.000
1.980
7.760
8.560
1.210
3.760
5.970

Assumptions for Combustion Emissions
Num. of
Type of Construction Equipment
HP Rated Hrs/day
Units
Water Truck
2
300
8
Diesel Road Compactors
1
100
8
Diesel Dump Truck
2
300
8
Diesel Excavator
2
300
8
Diesel Hole Trenchers
1
175
8
Diesel Bore/Drill Rigs
0
300
8
Diesel Cement & Mortar Mixers
1
300
8
Diesel Cranes
0
175
8
Diesel Graders
3
300
8
Diesel Tractors/Loaders/Backhoes
1
100
8
Diesel Bull Dozers
2
300
8
Diesel Front End Loaders
2
300
8
Diesel Fork Lifts
1
100
8
Diesel Generator Set
2
40
8

PM-10
g/hp-hr
0.410
0.340
0.410
0.320
0.460
0.500
0.480
0.340
0.330
1.370
0.330
0.350
1.390
0.730

130
15
130
60
15
60
60
130
15
90
15
30
130
130

Days/yr

PM-2.5
g/hp-hr
0.400
0.330
0.400
0.310
0.440
0.490
0.470
0.330
0.320
1.330
0.320
0.340
1.350
0.710

Total hphrs
624000
12000
624000
288000
21000
0
144000
0
108000
72000
72000
144000
104000
83200

SO2 g/hpCO2 g/hp-hr
hr
0.740
536.000
0.740
536.200
0.740
536.000
0.740
536.300
0.740
535.800
0.730
529.700
0.730
529.700
0.730
530.200
0.740
536.300
0.950
691.100
0.740
536.300
0.740
536.200
0.950
690.800
0.810
587.300

CALCULATION SHEET-COMBUSTION EMISSIONS-CONSTRUCTION

00004094

1.102E-06

Water Truck
Diesel Road Paver
Diesel Dump Truck
Diesel Excavator
Diesel Hole Cleaners\Trenchers
Diesel Bore/Drill Rigs
Diesel Cement & Mortar Mixers
Diesel Cranes
Diesel Graders
Diesel Tractors/Loaders/Backhoes
Diesel Bull Dozers
Diesel Front End Loaders
Diesel Aerial Lifts
Diesel Generator Set
Total Emissions

Conversion factors
Grams to tons

Type of Construction Equipment

Emission Calculations
CO
NOx
VOC tons/yr
tons/yr
tons/yr
0.303
1.423
3.775
0.005
0.020
0.065
0.303
1.423
3.775
0.108
0.413
1.460
0.012
0.056
0.134
0.000
0.000
0.000
0.097
0.368
1.155
0.000
0.000
0.000
0.042
0.162
0.563
0.147
0.651
0.573
0.029
0.109
0.378
0.060
0.246
0.793
0.227
0.889
0.981
0.111
0.345
0.547
1.442
6.106
14.200
PM-10
tons/yr
0.282
0.004
0.282
0.102
0.011
0.000
0.076
0.000
0.039
0.109
0.026
0.056
0.159
0.067
1.213

PM-2.5
tons/yr
0.275
0.004
0.275
0.098
0.010
0.000
0.075
0.000
0.038
0.106
0.025
0.054
0.155
0.065
1.180

SO2
tons/yr
0.509
0.010
0.509
0.235
0.017
0.000
0.116
0.000
0.088
0.075
0.059
0.117
0.109
0.074
1.918
368.579
7.091
368.579
170.209
12.399
0.000
84.057
0.000
63.828
54.835
42.552
85.089
79.171
53.847
1390.237

CO2 tons/yr

1. Emission factors (EF) were generated using USEPA's preferred model for nonroad sources, the NONROAD2008 model. Emmisions were modeled for the 2007 calendar year. The
VOC EFs includes exhaust and evaporative emissions. The VOC evaporative components included in the NONROAD2008 model are diurnal, hotsoak, running loss, tank permeation,
hose permeation, displacement, and spillage. The construction equipment age distribution in the NONROAD2008 model is based on the population in U.S. for the 2007 calendar year.

CALCULATION SHEET-COMBUSTION EMISSIONS-CONSTRUCTION

00004095

VOC

20
20
2
4
1

Miles traveled Days of travel Miles traveled
per day
per year
per year
60
260
312,000
60
260
312,000
60
260
31,200
130
260
135,200
130
260
33,800

2.892
5.449
2.158
2.273
3.610

CO (g/mile)
0.576
1.168
2.986
6.095
14.776

NOx (g/mile)
0.019
0.027
0.164
0.270
0.625

CO

NOx

0.006
0.009
0.007
0.047
0.027
0.095

PM-2.5

0.002
0.002
0.000
0.001
0.001
0.006

SO2

CO2 and CO2
Equivalents
110
151
21
138
75
496

CO2 and CO2
SO2 (g/mile) Equivalents
(g/mile)
0.005
320
0.007
439
0.005
609
0.007
929
0.016
2,020

1. Emission factors were generated by USEPA prefered model MOVES2010a. MOVES simulates daily motor vehicle operations and produces
emission rates. MOVES emission rates include sources from engine combustion, tire wear, brake wear, evaporative fuel permiation, vapor venting
and leaking (running and parking), and crankcase loss. Emission rates are daily averages for each of the criteria pollutants. The averages from a
comination of vehicle operations such as: stop and go, highway travel, acceleration at on-ramps, parking, start-up, extended idle, etc.

0.007
0.009
0.006
0.040
0.023
0.085

PM-10

0.018
0.025
0.190
0.313
0.726

PM-10 (g/mile) PM-2.5 (g/mile)

Emission Factors (MOVES 2010a Emission Rates) 1

Number of
vehicles

Total Emission for On-Road Construction Activities (tons/year)

8.497
3.645
4.460
2.438
2.519

VOC (g/mile)

Fuel type
Gasoline
Gasoline
Diesel
Diesel
Diesel

Passenger cars
2.921
0.994
0.198
Passenger truck
1.253
1.873
0.402
Light commercial truck
0.153
0.074
0.103
Short-haul truck
0.363
0.339
0.908
Long-haul truck
0.094
0.134
0.550
Total
4.785
3.415
2.161
Key:
Short-haul trucks catagory include trucks such as dump trucks and cement trucks.
Long-haul trucks category includes trucks such as semi-trailer (18 wheeler).

Source

Passenger cars
Passenger truck
Light commercial truck
Short-haul truck
Long-haul truck

Source

Source
Passenger cars
Passenger truck
Light commercial truck
Short-haul truck
Long-haul truck

MOVES 2010a

MOVES2010a MODEL ON-ROAD TRANSPORTATION AIR EMISSIONSDELIVERY MATERIALS AND COMMUTING DURING CONSTRUCTION ACTIVITIES

00004096

VOC

-

Miles traveled
per day
0
0
0
0
0

0.576
1.168
2.986
6.095
14.776

NOx (g/mile)

0.019
0.027
0.164
0.270
0.625

PM-10 (g/mile)

CO

NOx
0.00
0.00
0.00
0.00
0.00
0.00

PM-2.5
0.00
0.00
0.00
0.00
0.00
0.00

SO2
0.00
0.00
0.00
0.00
0.00
0.00

0.005
0.007
0.005
0.007
0.016

SO2 (g/mile)

CO2 and CO2
Equivalents
-

320
439
609
929
2,020

CO2 and CO2
Equivalents (g/mile)

1. Emission factors were generated by USEPA prefered model MOVES2010a. MOVES simulates daily motor vehicle operations and produces emission rates.
MOVES emission rates include sources from engine combustion, tire wear, brake wear, evaporative fuel permiation, vapor venting and leaking (running and
parking), and crankcase loss. Emission rates are daily averages for each of the criteria pollutants. The averages from a comination of vehicle operations such
as: stop and go, highway travel, acceleration at on-ramps, parking, start-up, extended idle, etc.

PM-10

0.018
0.025
0.190
0.313
0.726

PM-2.5 (g/mile)

Total Emission for On-Road Commuter Activities (tons/year)

2.892
5.449
2.158
2.273
3.610

CO (g/mile)

1

Days of travel Miles traveled per
per year
year
365
365
365
365
365
-

Emission Factors (MOVES 2010a Emission Rates)

Number of
vehicles

Passenger cars
0.00
0.00
0.00
Passenger truck
0.00
0.00
0.00
Light commercial truck
0.00
0.00
0.00
Short-haul truck
0.00
0.00
0.00
Long-haul truck
0.00
0.00
0.00
Total
0.00
0.00
0.00
Key:
Short-haul trucks catagory include trucks such as dump trucks and cement trucks.
Long-haul trucks category includes trucks such as semi-trailer (18 wheeler).

Source

8.497
3.645
4.460
2.438
2.519

VOC (g/mile)

Source

Passenger cars
Passenger truck
Light commercial truck
Short-haul truck
Long-haul truck

Fuel type
Gasoline
Gasoline
Diesel
Diesel
Diesel

Source
Passenger cars
Passenger truck
Light commercial truck
Short-haul truck
Long-haul truck

MOVES 2010a

MOVES2010a MODEL ON-ROAD TRANSPORTATION AIR EMISSIONS- ONGOING OPERATIONS

00004097

PM2.5 controlled
0.44
0.02
0.46

acres per feet
feet per mile

MRI 1996. Improvement of Specific Emission Factors (BACM Project No. 1). Midwest Research Institute (MRI). Prepared for the California South Coast Air Quality
Management District, March 29, 1996.

USEPA 2006. Documentation for the Final 2002 Nonpoint Sector (Feb 06 version) National Emission Inventory for Criteria and Hazardous Air Pollutants.Prepared for:
Emissions Inventory and Analysis Group (C339-02) Air Quality Assessment Division Office of Air Quality Planning and Standards, United States Environmental Protection
Agency. July 2006.

References:
USEPA 2001. Procedures Document for National Emissions Inventory, Criteria Air Pollutants, 1985-1999. EPA-454/R-01-006. Office of Air Quality Planning and Standards,
United States Environmental Protection Agency. March 2001.

PM10 uncontrolled
8.84
Construction Area (0.19 ton PM10/ac
Staging Areas
0.38
Total
9.22

2.00

Project Assumptions
Conversion Factors
0.000022957
5280

Project Emissions (tons/year)
PM10 controlled
PM2.5 uncontrolled
4.42
0.88
0.19
0.04
4.61
0.92

months
miles
feet
feet
acres

Staging Areas
Duration of Construction Project
Length
Length (converted)
Width
Area
8

months
miles
feet
feet
acres

(assume 50% control
efficiency for PM10 and
PM2.5 emissions)

0.50

Control Efficiency

Construction Area (0.19 ton PM10/acre-month)
Duration of Soil Disturbance in Projec
8
Length
2
Length (converted)
10560
Width
24
Area
5.82

EPA 2001; EPA 2006

(10% of PM10 emissions
assumed to be PM2.5)

0.10

PM2.5 Emissions
PM2.5 Multiplier
EPA 2001; EPA 2006

Source
MRI 1996; EPA 2001; EPA 2006
MRI 1996; EPA 2001; EPA 2006

Construction Fugitive Dust Emission Factors
Emission Factor
Units
0.19 ton PM10/acre-month
General Construction Activities
New Road Construction
0.42 ton PM10/acre-month

Assumptions for Combustion Emissions

CALCULATION SHEET-FUGITIVE DUST-CONSTRUCTION

00004098

EPA 2006. Documentation for the Final 2002 Nonpoint Sector (Feb 06 version) National Emission Inventory for Criteria and Hazardous Air Pollutants. Prepared for: Emissions Inventory and
Analysis Group (C339-02) Air Quality Assessment Division Office of Air Quality Planning and Standards, United States Environmental Protection Agency. July 2006.
MRI 1996. Improvement of Specific Emission Factors (BACM Project No. 1). Midwest Research Institute (MRI). Prepared for the California South Coast Air Quality Management District,
March 29, 1996.

References:
EPA 2001. Procedures Document for National Emissions Inventory, Criteria Air Pollutants, 1985-1999. EPA-454/R-01-006. Office of Air Quality Planning and Standards, United States
Environmental Protection Agency. March 2001.

Control Efficiency for PM10 and PM2.5
0.50
The EPA National Emission Inventory documentation recommends a control efficiency of 50% for PM10 and PM2.5 in PM nonattainment areas. Wetting controls will be applied during project
construction (EPA 2006).

PM2.5 Multiplier
0.10
PM2.5 emissions are estimated by applying a particle size multiplier of 0.10 to PM10 emissions. This methodology is consistent with the procedures documents for the National Emission
Inventory (EPA 2006).

0.42 ton PM10/acre-month Source: MRI 1996; EPA 2001; EPA 2006
The emission factor for new road construction is based on the worst-case conditions emission factor from the MRI 1996 study described above (0.42 tons PM10/acre-month). It is assumed that
road construction involves extensive earthmoving and heavy construction vehicle travel resulting in emissions that are higher than other general construction projects. The 0.42 ton PM10/acremonth emission factor for road construction is referenced in recent procedures documents for the EPA National Emission Inventory (EPA 2001; EPA 2006).

New Road Construction Emission Factor

The 0.19 ton PM10/acre-month emission factor is referenced by the EPA for non-residential construction activities in recent procedures documents for the National Emission Inventory (EPA
2001; EPA 2006). The 0.19 ton PM10/acre-month emission factor represents a refinement of EPA's original AP-42 area-based total suspended particle (TSP) emission factor in Section 13.2.3
Heavy Construction Operations. In addition to the EPA, this methodology is also supported by the South Coast Air Quality Management District and the Western Regional Air Partnership
(WRAP) which is funded by the EPA and is administered jointly by the Western Governor's Association and the National Tribal Environmental Council. The emission factor is assumed to
encompass a variety of non-residential construction activities including building construction (commercial, industrial, institutional, governmental), public works, and travel on unpaved roads.
The EPA National Emission Inventory documentation assumes that the emission factors are uncontrolled and recommends a control efficiency of 50% for PM10 and PM2.5 in PM
nonattainment areas.

0.19 ton PM10/acre-month Source: MRI 1996; EPA 2001; EPA 2006
The area-based emission factor for construction activities is based on a study completed by the Midwest Research Institute (MRI) Improvement of Specific Emission Factors (BACM Project No.
1), March 29, 1996. The MRI study evaluated seven construction projects in Nevada and California (Las Vegas, Coachella Valley, South Coast Air Basin, and the San Joaquin Valley). The
study determined an average emission factor of 0.11 ton PM10/acre-month for sites without large-scale cut/fill operations. A worst-case emission factor of 0.42 ton PM10/acre-month was
calculated for sites with active large-scale earth moving operations. The monthly emission factors are based on 168 work-hours per month (MRI 1996). A subsequent MRI Report in 1999,
Estimating Particulate Matter Emissions from Construction Operations, calculated the 0.19 ton PM10/acre-month emission factor by applying 25% of the large-scale earthmoving emission
factor (0.42 ton PM10/acre-month) and 75% of the average emission factor (0.11 ton PM10/acre-month).

General Construction Activities Emission Factor

Assumptions for Fugitive Emissions

00004099

1.44
NA

4.78

6.23
100

Combustion Emissions

Construction Site-Fugitive PM-10

Construction Workers Commuter
& Trucking

Total emissionsCONSTRUCTION

De minimis Threshold (1)
100

9.52

3.42

NA

6.11

CO

100

16.36

2.16

NA

14.20

NOx

70

5.91

0.08

4.61

1.21

PM-10

100

1.74

0.09

0.46

1.18

PM-2.5

Conversion
Factor
311
25

Source: EPA 2010 Reference, Tables and Conversions, Inventory of U.S. Greenhouse Gas Emissions and Sinks;
http://www.epa.gov/climatechange/emissions/usinventoryreport.html

Carbon Equivalents
N2O or NOx
Methane or VOCs

1. Note that Imperial County is in non-attainment for Ozone, PM-10 (serious), and PM 2.5 (USEPA 2010b and CARB 2012).

VOC

Emission Source

Assumptions for Combustion Emissions

CALCULATION SHEET-SUMMARY OF EMISSIONS

100

1.92

0.01

NA

1.92

SO2

NA

1390

NA

NA

1390.24

CO2

NA

NA

4,948

496

4,452

CO2 Equivalents

496

25,000

6,338

NA

5,843

Total CO2

00004100

00004101

Final
ENVIRONMENTAL ASSESSMENT
FOR THE PROPOSED INSTALLATION, OPERATION, AND
MAINTENANCE OF PRIMARY PEDESTRIAN FENCE
NEAR LUKEVILLE, ARIZONA
U.S. BORDER PATROL
TUCSON SECTOR

U.S. Department of Homeland Security
U.S. Customs & Border Protection
U.S. Border Patrol
Washington, D.C.

February 2008

Final

ENVIRONMENTAL ASSESSMENT
FOR THE PROPOSED INSTALLATION, OPERATION, AND
MAINTENANCE OF PRIMARY PEDESTRIAN FENCE
NEAR LUKEVILLE, ARIZONA
U.S. BORDER PATROL
TUCSON SECTOR
January 2008

Lead Agency:

U.S. Customs and Border Protection
Asset Management Division
Portfolio Management Branch
Room 3.4-D
1300 Pennsylvania Avenue, N.W.
Washington, D.C. 20229

Point of Contact:

Mr. George Hutchinson
U.S. Customs and Border Protection
Room 3.4-D
1300 Pennsylvania Avenue, N.W.
Washington, D.C. 20229

EXECUTIVE SUMMARY
BACKGROUND:

National Park Service (NPS) issued a Finding of No Significant
Impact (FONSI) and Final Environmental Assessment (EA) for the
Proposed Permanent Vehicle Barriers (PVB) in 2003, which
addressed the construction of PVBs across the southern boundary
of the Organ Pipe Cactus National Monument (OPCNM) in Pima
County, Arizona. The PVBs span approximately 30 miles of the
United States (U.S.) – Mexico border. The PVBs constructed by
the NPS have served effectively and efficiently in deterring and
hindering illegal vehicle traffic on the OPCNM.

PURPOSE AND
NEED FOR THE
PROPOSED
PROJECT:

The purpose of the proposed primary pedestrian fence is to help
U.S. Customs and Border Protection (CBP) agents and officers
gain effective control of our nation’s borders. CBP is developing
and deploying the appropriate mix of technology, infrastructure,
and personnel. In some locations, primary pedestrian fence is a
critical element of border security. In alignment with Federal
mandates, U.S. Border Patrol (USBP) has identified this area of
the border as a location where primary pedestrian fence would
contribute significantly to their homeland security mission. The
need for the proposed action is to meet USBP operational
requirements; provide a safer environment for USBP agents, NPS
staff, and general public; deter illegal aliens (IAs) by constructing
an impediment to northward movement into the U.S.; enhance the
response time of USBP agents; and meet the mandates of Federal
legislation (i.e., Secure Fence Act of 2006 and 2007 Department of
Homeland Security [DHS] Appropriations Act [HR 5441]).

PROPOSED
ACTION:

The Proposed Action Alternative includes the construction and
maintenance of 5.2 miles of primary pedestrian fence along the
U.S.-Mexico border near Lukeville, Arizona. Approximately 3.1
miles and 2.1 miles of primary pedestrian fence would be installed
on the east and west sides of the Lukeville POE, respectively. The
primary pedestrian fence would be constructed approximately 3 feet
north of the existing PVBs with the exception of 0.65 miles over
Sonoyta Hill. Construction activities would remain within the 60-foot
Roosevelt Reservation with the exception of the western most 0.65
miles. The western most 0.65 miles, which would be built over
Sonoyta Hill, requires a construction footprint of 150 feet and the
fence would be built approximately 3 feet north of the U.S.-Mexico
border due to no PVBs existing over Sonoyta Hill.
The design selected for the primary pedestrian fence is a mesh
design. It would be 15 feet high and capable of withstanding a crash
from a 10,000-pound (gross weight) vehicle traveling at 40 miles per
hour. Currently, an existing patrol road parallels most of the border
in the project corridor, which would also be used for access during
construction of the primary pedestrian fence and as a maintenance
road when construction is completed. However, this road would

EA – Primary Fence, Ajo

iii

Final

need to be widened by approximately 30 feet to accommodate
construction equipment needed to install the fence.
This
construction/maintenance road would encompass the entire 60-foot
wide Roosevelt Reservation once completed. In addition, a new
road would need to be constructed in order to install the primary
pedestrian fence over Sonoyta Hill; this new road would be in the
westernmost 0.65 mile of the project corridor. CBP will be
responsible for maintaining the road, existing PVBs, and primary
pedestrian fence.
ALTERNATIVES TO
THE PROPOSED
ACTION:

Alternatives addressed in the EA include: Alternative 1: No Action
Alternative, which would preclude the construction of any primary
pedestrian fence, and Alternative 2: Proposed Action Alternative
(i.e., Preferred Alternative). The No Action Alternative would not
fully meet the mandate established by Federal legislation and only
incrementally enhances the detection, deterrence and
apprehension of IAs.

ENVIRONMENTAL
IMPACTS OF THE
PROPOSED
ACTION:

The Proposed Action Alternative would potentially result in
permanent impacts of up to 45 acres. However, approximately 17
acres of the project corridor have been previously disturbed from
the construction of the existing PVBs. Direct impacts to vegetation,
wildlife, unique and sensitive areas, and aesthetics would be
expected. Wildlife movement across the international boundary
would be impeded within the corridor, but these impacts would be
minimal to local or regional wildlife population. The viewshed of
the OPCNM would be impacted by the construction of the primary
pedestrian fence; however, once completed, the primary
pedestrian fence would afford greater safety to park visitors and
sensitive resources. Additionally, mitigation measures would be
implemented (i.e., using subdued and non-reflective materials) to
ensure impacts to aesthetics would not be considered significant.
No significant impacts on any human or natural resources either
locally or regionally would be expected upon implementation of the
Proposed Action Alternative.

CONCLUSIONS:

Based upon the results of this EA, it has been concluded that the
Proposed Action Alternative would not have a significant adverse
effect on the environment, and no additional National
Environmental Policy Act documentation is warranted.

EA – Primary Fence, Ajo

iv

Final

TABLE OF CONTENTS
EXECUTIVE SUMMARY ............................................................................................................. iii
1.0

INTRODUCTION AND PURPOSE AND NEED.............................................................1-1

1.1
1.2

1.3
1.4
1.5
1.6

INTRODUCTION............................................................................................................1-1
HISTORY AND BACKGROUIND ...................................................................................1-1
1.2.1 CBP History ........................................................................................................1-1
1.2.2 CBP Strategic Intent and Priorities .....................................................................1-2
1.2.3 Background ........................................................................................................1-3
LOCATION OF THE PROPOSED PROJECT................................................................1-3
PURPOSE AND NEED ..................................................................................................1-3
APPLICABLE ENVIRONMENTAL STATUTES AND REGULATIONS ..........................1-5
REPORT ORGANIZATION ............................................................................................1-6

2.0

ALTERNATIVES............................................................................................................2-1

2.1
2.2
2.3
2.4
2.5

NO ACTION ALTERNATIVE..........................................................................................2-1
PROPOSED ACTION ALTERNATIVE...........................................................................2-1
OTHER ALTERNATIVES EVALUATED BUT ELIMINATED FROM
CONSIDERATION .........................................................................................................2-4
2.3.1 Technology in Lieu of Tactical Infrastructure......................................................2-4
CONSTRUCTION PERSONNEL AND EQUIPMENT ....................................................2-4
SUMMARY.....................................................................................................................2-5

3.0

AFFECTED ENVIRONMENT ........................................................................................3-1

3.1
3.2
3.3

LAND USE .....................................................................................................................3-1
SOILS.............................................................................................................................3-2
BIOLOGICAL RESOURCES..........................................................................................3-2
3.3.1 Vegetation Communities ....................................................................................3-2
3.3.2 Wildlife................................................................................................................3-2
3.3.3 Non-Native and Invasive Species.......................................................................3-3
UNIQUE AND SENSITIVE AREAS................................................................................3-3
WILDERNESS ...............................................................................................................3-5
PROTECTED SPECIES AND CRITICAL HABITATS ....................................................3-5
3.6.1 Federal ...............................................................................................................3-5
3.6.1.1 Sonoran Pronghorn .............................................................................3-7
3.6.1.2 Lesser Long-nosed Bat........................................................................3-7
3.6.1.3 Acuña Cactus ......................................................................................3-9
3.6.2 State ...................................................................................................................3-9
3.6.3 Critical Habitat ..................................................................................................3-10
CULTURAL RESOURCES ..........................................................................................3-10
3.7.1 Cultural History .................................................................................................3-11
3.7.2 Previous Investigation ......................................................................................3-11
3.7.3 Current Investigation ........................................................................................3-11
AIR QUALITY...............................................................................................................3-12
WATER RESOURCES ................................................................................................3-12
SOCIOECONOMICS ...................................................................................................3-14
3.10.1 Environmental Justice ......................................................................................3-15

3.4
3.5
3.6

3.7

3.8
3.9
3.10

EA – Primary Fence, Ajo

v

Final

3.11
3.12
3.13

3.10.2 Protection of Children .......................................................................................3-15
NOISE ..........................................................................................................................3-16
AESTHETICS...............................................................................................................3-17
WASTE ........................................................................................................................3-18
3.13.1 Hazardous Waste .............................................................................................3-18
3.13.2 Unregulated Solid Waste..................................................................................3-18

4.0

ENVIRONMENTAL CONSEQUENCES ........................................................................4-1

4.1

LAND USE .....................................................................................................................4-2
4.1.1 Alternative 1: No Action Alternative ....................................................................4-2
4.1.2 Alternative 2: Proposed Action Alternative ........................................................4-2
SOILS.............................................................................................................................4-3
4.2.1 Alternative 1: No Action Alternative ...................................................................4-3
4.2.2 Alternative 2: Proposed Action Alternative ........................................................4-3
BIOLOGICAL RESOURCES..........................................................................................4-4
4.3.1 Vegetation Communities ....................................................................................4-4
4.3.1.1 Alternative 1: No Action Alternative ....................................................4-4
4.3.1.2 Alternative 2: Proposed Action Alternative .........................................4-4
4.3.2 Wildlife................................................................................................................4-5
4.3.2.1 Alternative 1: No Action Alternative ....................................................4-5
4.3.2.2 Alternative 2: Proposed Action Alternative .........................................4-5
4.3.3 Non-native and invasive species ........................................................................4-6
4.3.3.1 Alternative 1: No Action Alternative .....................................................4-6
4.3.3.2 Alternative 2: Proposed Action Alternative ..........................................4-6
UNIQUE AND SENSITIVE AREAS................................................................................4-7
4.4.1 Alternative 1: No Action Alternative ...................................................................4-7
4.4.2 Alternative 2: Proposed Action Alternative ........................................................4-7
WILDERNESS ...............................................................................................................4-8
4.5.1 Alternative 1: No Action Alternative ....................................................................4-8
4.5.2 Alternative 2: Proposed Action Alternative ........................................................4-8
PROTECTED SPECIES AND CRITICAL HABITAT ....................................................4-10
4.6.1 Alternative 1: No Action Alternative .................................................................4-10
4.6.2 Alternative 2: Proposed Action Alternative ......................................................4-10
4.6.3 Critical habitat...................................................................................................4-12
CULTURAL RESOURCES ..........................................................................................4-13
4.7.1 Alternative 1: No Action Alternative ..................................................................4-13
4.7.2 Alternative 2: Proposed Action Alternative ......................................................4-13
AIR QUALITY...............................................................................................................4-13
4.8.1 Alternative 1: No Action Alternative .................................................................4-13
4.8.2 Alternative 2: Proposed Action Alternative ......................................................4-14
WATER RESOURCES ................................................................................................4-15
4.9.1 Alternative 1: No Action Alternative .................................................................4-15
4.9.2 Alternative 2: Proposed Action Alternative ......................................................4-15
SOCIOECONOMICS ...................................................................................................4-17
4.10.1 Alternative 1: No Action Alternative .................................................................4-17
4.10.2 Alternative 2: Proposed Action Alternative ......................................................4-17
NOISE ..........................................................................................................................4-18
4.11.1 Alternative 1: No Action Alternative .................................................................4-18
4.11.2 Alternative 2: Proposed Action Alternative ......................................................4-18
AESTHETICS...............................................................................................................4-18

4.2
4.3

4.4
4.5
4.6

4.7
4.8
4.9
4.10
4.11
4.12

EA – Primary Fence, Ajo

vi

Final

4.13

4.12.1 Alternative 1: No Action Alternative .................................................................4-18
4.12.2 Alternative 2: Proposed Action Alternative ......................................................4-19
HAZARDOUS AND SOLID WASTE.............................................................................4-19
4.13.1 Alternative 1: No Action Alternative .................................................................4-19
4.13.2 Alternative 2: Proposed Action Alternative ......................................................4-19

5.0

CUMULATIVE IMPACTS ..............................................................................................5-1

6.0

MITIGATION MEASURES.............................................................................................6-1

6.1
6.2
6.3
6.4
6.5
6.6
6.7
6.8

GENERAL CONSTRUCTION ACTIVITIES....................................................................6-1
SOILS.............................................................................................................................6-2
BIOLOGICAL RESOURCES..........................................................................................6-2
CULTURAL RESOURCES ............................................................................................6-3
WATER RESOURCES ..................................................................................................6-4
AIR QUALITY.................................................................................................................6-4
NOISE ............................................................................................................................6-4
AESTHETICS.................................................................................................................6-5

7.0

PUBLIC INVOLVEMENT ...............................................................................................7-1

7.1
7.2

AGENCY COORDINATION ...........................................................................................7-1
PUBLIC REVIEW ...........................................................................................................7-1

8.0

REFERENCES...............................................................................................................8-1

9.0

LIST OF PREPARERS ..................................................................................................9-1

10.0

ACRONYMS ................................................................................................................10-1

EA – Primary Fence, Ajo

vii

Final

LIST OF FIGURES
Figure 1-1. Vicinity Map ............................................................................................................1-4
Figure 2-1. Proposed Action Alternative ...................................................................................2-2
Figure 3-1. Range of Sonoran Pronghorn.................................................................................3-8
LIST OF TABLES
Table 2-1. Relationship between Purpose and Need and Project ............................................2-5
Table 2-2. Summary Matrix.......................................................................................................2-6
Table 3-1. Federally Listed and Proposed Species Potentially Occurring Within Pima
County, Arizona.......................................................................................................3-6
Table 4-1. Total Air Emissions (tons/year) from Construction Activities .................................4-14
Table 5-1. Recently Completed or Reasonably Foreseeable USBP projects in Ajo
Station’s AO ............................................................................................................5-2
LIST OF PHOTOGRAPHS
Photograph 3-1. Trails and trash left by IAs near Lukeville, Arizona POE..............................3-17
Photograph 3-2. View of Sonoyta, Mexico residential areas from U.S. Border near Lukeville,
Arizona .......................................................................................................3-17
Photograph 3-3. Lukeville, Arizona-Sonoyta, Mexico POE.....................................................3-17
LIST OF EXHIBITS
Exhibit 2-1. Example of Mesh Fence Design ............................................................................2-3
Exhibit 4-1. Schematic Representation of View from South Puerto Blanco Road Facing
Southwest ...............................................................................................................4-9
Exhibit 4-2. Schematic Representation of View from South Puerto Blanco Road Facing
Southeast ................................................................................................................4-9
LIST OF APPENDICES
Appendix A.
Appendix B.
Appendix C.
Appendix D.

March 2006 Memorandum of Understanding
List of State and Federal Protected Species for Pima County
Correspondence
Air Quality Calculations

EA – Primary Fence, Ajo

viii

Final

SECTION 1.0
INTRODUCTION AND PURPOSE AND NEED

1.0

INTRODUCTION AND PURPOSE AND NEED

1.1

INTRODUCTION

This Environmental Assessment (EA) addresses the potential effects, beneficial and adverse, of
the proposed installation of 5.2 miles of primary pedestrian fence near Lukeville, Arizona. The
action is proposed by United States (U.S.) Border Patrol (USBP) Tucson Sector and would
occur in the Ajo Station’s Area of Operation (AO). This EA is tiered from the 2001 Supplemental
Programmatic Environmental Impact Statement (SPEIS) for Immigration and Naturalization
Service (INS) and Joint Task Force 6 (JTF-6) Activities along the U.S.-Mexico Border (INS 2001).
The SPEIS was developed in an attempt to provide the public with USBP’s assessment of
impacts as they relate to potential future infrastructure projects. Mentioned in the SPEIS is the
potential to construct fence, roads, and other infrastructure along the U.S.-Mexico border including
Arizona. In addition, information was gleaned from and incorporated by reference from the
National Park Service (NPS), Organ Pipe Cactus National Monument (OPCNM) Finding of No
Significant Impact (FONSI) and Final EA for the Proposed Permanent Vehicle Barriers (PVB)
December 2003 (NPS 2003). The OPCNM Final EA addressed the proposed construction of
approximately 30 miles of PVB along OPCNM’s U.S.-Mexico border.
This EA was prepared in accordance with the National Environmental Policy Act (NEPA) of 1969,
the Council on Environmental Quality (CEQ) Regulations implementing NEPA (Title 40 of the U.S.
Code of Federal Regulations [CFR], Parts 1500-1508), and Department of Homeland Security
(DHS) Management Directive 5100.1, which is the Environmental Planning Program Directive that
outlines DHS’s procedures for the implementation of NEPA.
1.2

HISTORY AND BACKGROUIND

1.2.1

CBP History

In 1924, Congress created USBP to serve as the law enforcement entity of INS, which it did until
November 25, 2002. With the passage of the Homeland Security Act of 2002 (Public Law 107296), DHS was established to reorganize Federal law enforcement and border protection
agencies into a single department. USBP was officially transferred into the Office of Border
Patrol, under DHS, U.S. Customs and Border Protection (CBP), on March 1, 2003.

EA – Primary Fence, Ajo

1-1

Final

1.2.2

CBP Strategic Intent and Priorities

The priority mission of CBP is to prevent terrorists and terrorist weapons from entering the U.S.
This priority mission involves maintaining a diverse, multi-layered approach, which includes
improving security at the international borders and ports of entry (POE). It also extends the
physical zone of security beyond the Nation’s physical borders so that U.S. borders are the last
line of defense, not the first (CBP 2003). As part of this mission, CBP has implemented its
Comprehensive Strategy to Address the Threat of Nuclear and Radiological Terrorism to identify
and seize terrorists’ assets and funding sources and enhance the support infrastructure to further
develop targets and analyses.
In addition to carrying out its priority mission, CBP must fulfill its traditional missions including:
•

controlling the sovereign borders of the U.S. by apprehending individuals
attempting to enter the U.S. illegally;

•

stemming the flow of illegal drugs and other contraband;

•

protecting the Nation’s agriculture and economic interest from harmful pests and
diseases;

•

facilitating international trade;

•

collecting import duties; and

•

enforcing U.S. trade, immigration and other laws of the U.S. at and beyond the
Nation’s borders (CBP 2003).

Hereinafter, any individual, including terrorists and smugglers, who attempt to illegally enter the
U.S. between POEs is referred to as an illegal alien (IA).
The mission of USBP is to strengthen the U.S. borders to prevent the entry of IAs, terrorist
weapons, narcotics and other contraband. The principle objective of USBP is to apply appropriate
levels of USBP personnel, intelligence, technology, and infrastructure resources to increase the
level of operational effectiveness until the likelihood of apprehension is sufficient to be an effective
deterrent that conveys an absolute certainty of detection and apprehension.
During recent years, USBP has significantly increased its emphasis on deterrence. Deterrence
is achieved only when USBP has the ability to create and convey the immediate, credible, and
absolute certainty of detection and apprehension. As such, tactical infrastructure components,
such as pedestrian barriers and roads are a critical element. Trends such as the continued
urbanization and industrialization of the immediate border, the recognition of environmental
EA – Primary Fence, Ajo

1-2

Final

preservation concerns, and the increase of criminal trans-boundary activities (including
trafficking in people, drugs, and terrorism efforts) continue as a border enforcement challenge
and increase the need for tactical infrastructure along the international borders.
1.2.3

Background

NPS issued a Final EA and FONSI in 2003, which addressed the construction of PVBs along
the southern boundary of OPCNM (NPS 2003). The PVBs extend across the entire southern
boundary of OPCNM along the U.S.-Mexico border except over Sonoyta Hill.

All of the

construction activities completed while building the PVBs were located within the 60-foot
Roosevelt Reservation. To date, the entire 30 miles of planned PVBs have been completed by
NPS. The PVBs constructed by NPS have served effectively and efficiently in deterring and
hindering illegal vehicle traffic on OPCNM; however, PVBs do not deter pedestrian traffic.
1.3

LOCATION OF THE PROPOSED PROJECT

The general location of the proposed project was previously discussed in the December 2003
Final EA (NPS 2003) and is incorporated herein by reference. The project corridor is located
along the U.S.-Mexico border near Lukeville, Arizona (Figure 1-1).
1.4

PURPOSE AND NEED

The purpose and need for the NPS 2003 Final EA was to prevent illegal vehicle traffic from
degrading the biological resources of OPCNM as well as to protect the health and safety of
Federal staff and visitors. The construction of the PVBs met the stated purpose and need of the
NPS 2003 Final EA. However, since the completion of the NPS 2003 Final EA, shifts in IA
traffic and recent Federal legislation has required changes in the designs of border tactical
infrastructure. The purpose of the proposed primary pedestrian fence is to help CBP agents
and officers gain effective control of our nation’s borders.

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Final

60
£
¤

89
£
¤

17
§
¦
¨

10
§
¦
¨
Pima County

60
£
¤
80
£
¤

Buckeye

Phoenix

ARIZONA
Maricopa County

10
§
¦
¨

8
§
¦
¨

Casa
Grande

Pinal County
Yuma County

85
!
(

Ajo

Pima County
86
!
(

ORGAN PIPE CACTUS
NATIONAL
85
MONUMENT

!
(
Lukeville POE

Lukeville

Legend

0

Organ Pipe Cactus National Monument
Project Corridor

MEXICO

0
10
MEXICO

μ

10

20

1:1,000,000
20

30
Miles

30

40
Kilometers

Figure 1-1: Vicinity Map
August 2007

1-4

CBP is developing and deploying the appropriate mix of technology, infrastructure, and
personnel. In some locations, primary pedestrian fence is a critical element of border security.
In alignment with Federal mandates USBP has identified this area of the border as a location
where primary pedestrian fence would contribute significantly to their priority homeland security
mission. The need for the proposed action is to meet USBP operational requirements; provide a
safer environment for USBP agents, NPS staff, and general public; deter IAs by constructing an
impediment to northward movement into the U.S.; enhance the response time of USBP agents;
and meet the mandates of Federal legislation (i.e., Secure Fence Act of 2006 and 2007
Department of Homeland Security [DHS] Appropriations Act [HR 5441]).

1.5

APPLICABLE ENVIRONMENTAL STATUTES AND REGULATIONS

The applicable environmental statutes and regulations for this EA are similar to those of the
December 2003 Final EA (NPS 2003) and are hereby incorporated by reference. In summary,
this EA was prepared in accordance with, but not limited to the NEPA of 1969; Endangered
Species Act (ESA) of 1973, as amended; the National Historic Preservation Act (NHPA) of
1966, as amended; and the Archeological and Historical Preservation Act of 1974, as amended.
In addition to theses environmental statutes and regulations this EA is guided by Federal
legislation, DHS’s Management Directive 5100.1, Clean Air Act (CAA), Clean Water Act (CWA),
Noise Control Act, Resource Conservation and Recovery Act, and Toxic Substances Control
Act. Executive Orders (E.O.) bearing on the proposed action include E.O. 11988 (Floodplain
Management), E.O. 11990 (Protection of Wetlands), E.O. 12088 (Federal Compliance with
Pollution Control Standards), E.O. 12580 (Superfund Implementation), E.O. 12898 (Federal
Actions to Address Environmental Justice in Minority Populations and Low-Income Populations),
E.O. 13045 (Protection of Children from Environmental Health Risks and Safety Risks), E.O.
13101 (Greening the Government Through Waste Prevention, Recycling, and Federal
Acquisition), E.O. 13123 (Greening the Government Through Efficient Energy Management),
E.O. 13148 (Greening the Government Through Leadership in Environmental Management),
E.O. 13175 (Consultation and Coordination with Indian Tribal Governments), and E.O. 13186
(Responsibilities of Federal Agencies to Protect Migratory Birds).

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Final

1.6

REPORT ORGANIZATION

This report is organized into 10 major sections including this introduction. Section 2.0 describes
all alternatives considered for the project.

Section 3.0 discusses the environmental features

potentially affected by the project, while Section 4.0 discusses the environmental consequences
for each of the viable alternatives. Cumulative impacts are discussed in Section 5.0, mitigation
measures are discussed in Section 6.0, and public comments and the notice of Availability (NOA)
are presented in Section 7.0. Sections 8.0, 9.0, and 10.0 present a list of the references cited in
the document, a list of acronyms and abbreviations, and a list of the persons involved in the
preparation of this document.

Appendix A contains the March 2006 Memorandum of

Understanding while Appendix B is a list of state and Federal protected species for Pima County.
Appendix C contains correspondence that was sent and received during the preparation of this
EA. Appendix D contains the air quality calculations for the Proposed Action Alternative.

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Final

SECTION 2.0
ALTERNATIVES

2.0

ALTERNATIVES

Three alternatives were identified and considered during the planning stages of the proposed
project: No Action Alternative, Proposed Action Alternative, and Technology in Lieu of Tactical
Infrastructure Alternative. The Proposed Action Alternative and Preferred Action Alternative are
synonymous terms; however, for the purposes of this EA they will be referred to as the
Proposed Action Alternative. The following paragraphs describe the alternatives considered.
2.1

NO ACTION ALTERNATIVE

Under the No Action Alternative, no construction activities would occur. The existing PVBs would
continue to be maintained by NPS. The No Action Alternative does not meet the project’s purpose
and need, but has been carried forward for analysis, as required by CEQ regulations. The No
Action Alternative will form the basis for evaluation of other action alternatives.
2.2

PROPOSED ACTION ALTERNATIVE

Primary pedestrian fencing has proved invaluable in denying quick access to concealment and
escape opportunities for IAs inside the U.S. It performs a dual role in border security by acting
as a visual deterrent and a formidable physical barrier, impeding IAs and increasing the window
of time USBP agents have to respond to IAs attempting to breach the U.S.-Mexico border. The
Proposed Action Alternative includes the construction and maintenance 5.2 miles of primary
pedestrian fence along the U.S.-Mexico border near Lukeville, Arizona (Figure 2-1). The project
corridor would extend 2.1 miles to the west and 3.1 miles to the east of the Lukeville POE.
Approximately 5.2 miles of primary pedestrian fence would be constructed. Construction
activities would remain within the 60-foot Roosevelt Reservation with the exception of the
westernmost 0.65 miles. The westernmost 0.65 miles, which would be built over Sonoyta Hill,
requires a construction footprint of 150 feet.

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2-1

Final

2-2

0

0

0.5

0.25

0.25

0.5

0.75

New Primary Fence

PVB Retrofit

rt

o
0.75

1
Kilometers

Pu e

nc o

Source: UGSG 1:24,000 Lukeville, AZ quadrangle

μ

1:35,000

uth

SONOYTA HILL

So

Bla
1
Miles

Drive

Figure 2-1: Proposed Action Alternative

Lukeville POE

85

Why

Lukeville

85
V
U

Organ Pipe Cactus
National Monument

Ajo

September 2007

Pisinemo

86
V
U

ia n
Ind

The primary pedestrian fence would be installed approximately 3 feet north of the existing PVBs
with the exception of the Sonoyta Hill portion. Due to the lack of PVBs in this area, the fence
would be constructed approximately 3 feet north of the U.S.-Mexico border. An example of the
mesh fence design is shown in Exhibit 2-1. This design would be used and would meet design
performance measures, which dictate that the fence must:
•

extend 15 to 18 feet above ground and 3 to 6 feet below ground;

•

be capable of withstanding a crash of a 10,000-pound (gross weight) vehicle
traveling at 40 miles per hour;

•

be semi-transparent, as dictated by operational need;

•

be vandal resistant;

•

be designed to survive the extreme climate changes of a desert environment;

•

not impede the natural flow of water; and

•

allow for maintenance access to border monuments as required by the U.S.
Section, International Boundary and Water Commission.
Exhibit 2-1. Example of Mesh Fence Design

Furthermore, in most washes or arroyos, the primary pedestrian fence would be designed and
constructed to ensure proper conveyance of floodwaters and to eliminate the potential to cause
backwater flooding on either side of the U.S.-Mexico border. CBP will remove debris from the

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Final

fence within washes/arroyos immediately after rain events to ensure that no backwater flooding
occurs.
Staging areas and turnarounds would be located within the Roosevelt Reservation. Construction
access would include the use of the existing patrol road adjacent to the U.S.-Mexico border as
well as South Puerto Blanco Road in order to construct the primary pedestrian fence and road up
and over Sonoyta Hill. Additionally, the road, existing PVBs, and primary pedestrian fence would
be maintained by CBP to ensure the integrity of the road, PVBs, and primary pedestrian fence is
not compromised.
2.3

OTHER ALTERNATIVES EVALUATED BUT ELIMINATED FROM CONSIDERATION

One other alternative was evaluated but eliminated from further consideration due to
impediments to construction or failure to meet the purpose and need for the project. This
alternative is discussed in the following subsection.
2.3.1

Technology in Lieu of Tactical Infrastructure

Under this alternative, USBP would use radar, cameras, lights, and other technology to identify
illegal border crossings.

The use of technology is a critical component of SBInet and an

effective force multiplier that allows USBP to monitor large areas and deploy agents to where
they will be most effective. However, in the more populated areas within the Tucson Sector,
physical barriers represent the most effective means to control illegal entry into the U.S. The
use of technology alone would not provide a practical solution to achieving effective control of
the border in USBP Tucson Sector. Therefore, this alternative would not meet the purpose and
need as described in Section 1.4 and will not be carried forward for further analysis.
2.4

CONSTRUCTION PERSONNEL AND EQUIPMENT

Private contractors would complete the proposed construction and installation of the
infrastructure components. All project personnel will not exceed a speed limit of 25 miles per
hour within the OPCNM during construction and maintenance related activities. The project is
expected to be completed by December 2008. Equipment staging would be located within
previously disturbed areas to minimize potential effects to the environment. The equipment

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Final

anticipated to be used during the construction includes a backhoe, trencher, auger, crane,
bulldozer, front-end loader, flatbed truck, water truck and roller/compactor.
2.5

SUMMARY

The two alternatives carried forward for analysis are the No Action Alternative and Proposed
Action Alternative. An alternative matrix (Table 2-1) compares the two alternatives relative to the
purpose and need.

Table 2-2 presents a summary matrix of the impacts from the three

alternatives analyzed and how they affect the environmental resources in the region.
Table 2-1. Relationship between Purpose and Need and Project
Alternative 1:
No Action
Alternative

Requirements
Provide a safer work environment for the USBP
agents
Deter illegal pedestrian traffic by constructing an
impediment to northward movement
Satisfy Federal legislation

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2-5

Alternative 2:
Proposed
Action
Alternative

PARTIALLY

YES

NO

YES

NO

YES

Final

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2-6

Final

Proposed Action Alternative

If implemented, approximately 45 acres of wildlife habitat could be impacted; however,
approximately 17 acres within the project corridor is previously disturbed from the construction
of the existing PVBs. Therefore, no significant impacts are expected. Wildlife movement across
the international boundary would be impeded within the corridor; however, these impacts would
be minimal to wildlife, locally or regionally. Indirect impacts could occur to areas outside the
project corridor.

No impacts are
expected.

No impacts are
expected.

No impacts are
expected.

Vegetation

Wildlife

Unique and
Sensitive Areas

2-6

No impacts are expected

Up to 28 acres of vegetation would be permanently altered. The remaining 17 acres of the
total footprint of the project corridor are previously disturbed. The 28 acres that would be
affected are comprised of vegetation communities that are regionally and locally common.
Thus, no significant impacts would be expected. Indirect impacts could occur to areas outside
the project corridor.

No impacts are
expected.

Soils

Wilderness

Up to 45 acres of soils could be permanently impacted. No prime farmlands would be
impacted. Indirect impacts could occur to areas outside the project corridor. No significant
impacts would occur as a result of the Proposed Action Alternative.

No impacts are
expected.

Land Use

The project footprint is primarily located within the Roosevelt Reservation. The viewshed of
the OPCNM would be impacted by the construction of the primary pedestrian fence; however,
once completed, the primary pedestrian fence will afford greater safety to park visitors and
sensitive resources. Indirect impacts could occur as construction is ongoing or by IAs outside
of the corridor if they try to circumvent the proposed infrastructure.
No direct impacts are expected. Indirect impacts could occur if IAs attempt to circumvent the
proposed infrastructure. USBP would use the primary pedestrian fence as a force multiplier,
which would all USBP to deploy agents to areas lacking infrastructure, thus, minimizing any
indirect impacts.

Approximately 7 acres (0.65 mile X 90 feet) of NPS lands over Sonoyta Hill would be used as
USBP infrastructure. The lands would remain as NPS lands; however, USBP would be
allowed use of the 7 acres as articulated through a Special Use Permit. The remainder of the
project corridor is within the Roosevelt Reservation; therefore, land use would not change in
these areas. No significant impacts are expected as the indirect beneficial impacts would
greatly outweigh the minor direct impacts. No significant impacts are expected as the indirect
beneficial impacts would greatly outweigh the minor direct impacts.

No Action Alternative

Affected
Environment

Table 2-2. Summary Matrix

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2-7

Final

Minor, temporary impacts could occur. Indirect beneficial impacts would occur within the
region due to the reduction of IA foot traffic and the associated societal cost.
The project corridor is located adjacent to the busy Lukeville POE; therefore, the impacts
would be minimal and temporary. No significant impacts to ambient noise levels would occur.
The project footprint is located within or adjacent to previously disturbed areas. The visibility of
the primary pedestrian fence from within the OPCNM would have minimal adverse impacts;
however, the beneficial impacts from the reduction of IAs and associated trash would be
expected to outweigh any adverse impacts. No significant impacts would occur. Indirect
impacts could occur outside of the project corridor.

No impacts are
expected.

No impacts are
expected.

No impacts are
expected.

Socioeconomics

Noise

Aesthetics

2-7

Up to 11.4 acre-feet of groundwater would be used for dust suppression and mixing concrete.
All water will be trucked into the project site from sources north of the OPCNM (i.e., Why, Ajo,
or Gila Bend). No deficit would occur to the region’s available groundwater sources; therefore,
no significant impacts to water resources would occur.

No impacts are
expected.

Pima County is in attainment for all criteria pollutants. Minor, temporary impacts would occur
during construction but would cease upon completion of the Proposed Action Alternative.

No impacts are
expected.

Air Quality

Water
Resources

No cultural resources would be impacted either directly or indirectly.

No impacts are
expected.

Cultural
Resources

Although approximately 17 acres of the total project footprint (45 acres) have been previously
disturbed due to the construction of the existing PVBs, food sources (columnar cacti) for the
lesser long-nosed bat (Leptonycteris curasoae yerbabuenae) and habitat for the Sonoran
pronghorn (Antilocapra americana sonoriensis) would be impacted. The Proposed Action
Alternative may affect and is likely to adversely affect these two species. Section 7
consultation is on-going with the U.S. Fish and Wildlife Service (USFWS); conservation
measures have been identified and would be implemented to off-set impacts to the bat and
pronghorn. Indirect impacts could occur to habitat or species outside of the corridor if IAs
attempt to circumvent the proposed infrastructure.

Proposed Action Alternative

No impacts are
expected.

No Action Alternative

Protected
Species

Affected
Environment

Table 2-2, continued

2-8

THIS PAGE LEFT INTENTIONALLY BLANK

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Final

SECTION 3.0
AFFECTED ENVIRONMENT

3.0

AFFECTED ENVIRONMENT

In accordance with CEQ regulations (40 CFR § 1502.15), this chapter of the EA describes the
baseline environment of the area(s) that would be affected by the viable alternatives under
consideration. Data and analyses are commensurate with the importance of the impact, with
less important material summarized, consolidated, or simply referenced.

For those resources

that have not changed, or where updates were not required, the discussions presented in the
NPS 2003 Final EA are incorporated by reference (NPS 2003). Each of these resources is
identified as such.
Resources such as prime farmlands, geology, communications, climate, and Wild and Scenic
Rivers would not be impacted by this project and, thus, will not be evaluated in this EA for the
following reasons:
•
•

Geology: The construction activities proposed for this project do not include
practices that would alter the geology of the area. These activities would result in
negligible and localized effects to geological features, primarily due to the
construction of concrete fence foundations and minimal cut and fill activities over
Sonoyta Hill.

•

Communications: The project would not affect communications systems in the
area.

•

Climate: The project would not affect nor be affected by the climate.

•

3.1

Prime Farmlands: There are no prime or unique farmlands in the project area.

Wild and Scenic Rivers: The proposed project would not affect any designated
Wild and Scenic Rivers because no rivers designated as such are located within
the project corridor.

LAND USE

This section was discussed in the 2003 Final EA and is incorporated herein by reference (NPS
2003). OPCNM is used for public use and recreation, species conservation, and as an
International Biosphere Reserve. However, the project corridor is located within the Roosevelt
Reservation along the U.S.-Mexico border. In March 2006, a Memorandum of Understanding
(MOU) was established between DHS, U.S. Department of the Interior, and U.S. Department of
Agriculture stating that all parties recognize that CBP operation and construction within the
Roosevelt Reservation is the intended land use of the reservation (see Appendix A). Thus, land
use within the majority of the project corridor is USBP infrastructure and operations.

The

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Final

3-1

construction footprint over Sonoyta Hill and the use of South Puerto Blanco Road are north of
the 60-foot Roosevelt Reservation and would require the issuance of a Special Use Permit by
the NPS.
3.2

SOILS

Soils found within the project corridor were previously discussed in the 2003 Final EA and are
hereby incorporated by reference (NPS 2003). No prime farmlands are located in the project
corridor. There are 7 soils series found within the project corridor, as follows:
•
•
•
•
•
•
•

Antho fine sandy loam
Gilman very fine sandy loam, saline
Gunsight very gravelly loam, 2-15% slopes
Harqua very gravelly loam, 0-3% slopes
Harqua-Gunsight complex
Lomitas very stony loam, 8-40% slopes
Torrifluvents (wash beds)

3.3

BIOLOGICAL RESOURCES

3.3.1

Vegetation Communities

Vegetation communities within the project corridor were discussed in the 2003 NPS Final EA
and are incorporated herein by reference (NPS 2003). In general, the dominant biotic
community of OPCNM is the mixed Sonoran desertscrub. This community is predominantly
composed of palo verde (Cercidium spp.), organ pipe cactus (Stenocereus thurberi), saguaro
(Carnegiea gigantea), ocotillo (Fouquieria splendens), Sonora barrel cactus (Ferocactus
covillei), California barrel cactus (Ferocactus cylindraceus), and brittlebush (Encelia farinosa)
(INS 2001).

The creosote-bursage vegetation community is the second most common

vegetation community on OPCNM and is comprised of creosotebush (Larrea tridentata), white
bursage (Ambrosia dumosa), and triangle-leaf bursage (Ambrosia deltoidea) (NPS 2003).
Saltbush (Atriplex sp.) is common throughout most of the project corridor, especially east of the
Lukeville POE (Baiza 2007).
3.3.2

Wildlife

A detailed discussion of wildlife resources was presented in the 2003 NPS Final EA and is
incorporated herein by reference (NPS 2003). In summary, a large diversity of animal species

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Final

are known to occur on OPCNM; these species include 55 mammals, 277 bird species, 48
reptiles and amphibians, one fish and two invertebrates. Many of the wildlife species found on
OPCNM are obligate desert species; however, the riparian habitat available at Quitobaquito and
Aquajita Springs support some aquatic species such as the Sonoran toad (Bufo alvarius) and
Quitobaquito pupfish (Cyprinodon macularius).
3.3.3

Non-Native and Invasive Species

Non-native vegetation was previously discussed in the 2003 Final EA and is incorporated herein
by reference (NPS 2003).

Although the OPCNM has a minimal amount of non-native or

invasive species in relation to the overall habitat area, these species have become a major
problem in certain areas. One such area is Quitobaquito Springs. The common non-native
species observed on the OPCNM include buffelgrass (Pennistetum ciliare), blue panic (Panicum
antidotale), and ice plants (Mesambryantheumum sp.).

More specifically, the common non-

native plant located in the project corridor is Bermuda grass (Cynodon dactylon) (Baiza 2007).
3.4

UNIQUE AND SENSITIVE AREAS

Southwestern Arizona has many unique and sensitive areas.

Ongoing efforts by many

government agencies, as well as private entities, have set aside areas for preservation. These
areas are intended for use by the public in hopes of better understanding the myriad of biological
and physical systems exhibited in their natural state. The unique or sensitive areas located within
or near the project corridor are discussed below.
Organ Pipe Cactus National Monument
OPCNM was established in 1937 by President Franklin D. Roosevelt to “celebrate the life and
landscape of the Sonoran desert” (Desert USA 2004a). In 1976, the United Nations designated
OPCNM as an International Biosphere Reserve; it is an almost pristine example of the Sonoran
Desert (NPS 2005). In OPCNM, three distinctive desert habitats (i.e., desert wilderness, vast
mountain ranges, and plains) converge within 500 square miles, representing diverse plant
communities (Desert USA 2004b). OPCNM encompasses approximately 330,000 acres, of which
312,600 acres, or 94 percent, are designated as Wilderness Area (NPS 2004). With 26 species
of cacti, OPCNM exhibits an extraordinary collection of plants of the Sonoran desert, including the
organ pipe cactus, which is rarely found in the U.S. (NPS 2004). Within the project corridor lies
components (i.e., xeroriparian areas and rocky hillsides) that make up the Sonoran Desert

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ecosystem for which the OPCNM was set aside to preserve. These components are common
throughout the Sonoran Desert, although the concentrations of certain Sonoran Desert species
(e.g., organ pipe, senita) are higher within the OPCNM.
Cabeza Prieta National Wildlife Refuge (CPNWR)
CPNWR shares 56 miles of border with Sonora, Mexico, and is home to seven mountain ranges
(USFWS 2002, Defenders of Wildlife 2004). CPNWR, established in 1939 to conserve natural
wildlife resources (e.g., desert bighorn sheep [Ovis canadensis mexicana]), occupies 860,010
acres and is the third largest National Wildlife Refuge in the contiguous 48 states (USFWS
2002, 2005).

The Arizona Desert Wilderness Act of 1990 designated over 90 percent

(approximately 799,000 acres) of CPNWR as Wilderness Area making it the largest Wilderness
Area in the state of Arizona (Arizona Wilderness Coalition 2004). CPNWR supports more than
391 plant species and 300 wildlife species, including the Federally listed Sonoran pronghorn
(Antilocapra americana sonoriensis) (USFWS 2002). The refuge is characterized by creosote
and bursage flats, ocotillo, western honey mesquite (Prosopsis glandulosa), palo verde,
ironwood (Olneya tesota), and an abundance of cacti, including cholla (Opuntia spp.) and
saguaro.
Barry M. Goldwater Range (BMGR)
BMGR, established in 1941 as an aerial gunnery and bombing range, lies to the north and west of
the project corridor and CPNWR. BMGR is a 1.7 million acre military tactical aviation training area
with 57,000 cubic miles of restricted airspace. It is the second largest range within Department of
Defense, and at one time over 2.7 million acres were set aside for the range.

Within the

boundaries of BMGR, at least 100 important cultural resource sites have been identified, three
BLM designated areas of critical environmental concern, and the Flat-tailed Horned Lizard
Management Area (BMGR Visitor Information Brochure, n.d.).

The “southern westernmost”

boundary of BMGR shares approximately 37 miles with the U.S.-Mexico border (U.S. Department
of Air Force et al. 2006).
The Tohono O’odham Nation
Tohono O’odham Nation (TON) is comprised of four non-contiguous areas (Inter Tribal Council of
Arizona 2003). The largest of the four areas within TON is located east of the project corridor.
This area stretches 70 miles across the U.S.-Mexico border and occupies 2,773,357 acres. The
total population of TON was 23,750 in 1999 (Arizona Department of Commerce 2004). The town

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of Sells serves as the Nation’s capital and other small, scattered villages are located within TON.
Members of the Nation live in both the U.S. and Mexico.
3.5

WILDERNESS

The Wilderness Act of 1964 allowed for the establishment of a National Wilderness Preservation
System. The act allows for the establishment of wilderness on Federally owned lands designated
by Congress. Areas designated as wilderness are to be administered for the use and enjoyment
of the public in such a manner as to leave the lands undisturbed for future use and enjoyment as
wilderness, and to provide protection of these areas, and the preservation of their wilderness
character. To maintain the wilderness characteristics of designated wilderness areas certain
activities are prohibited and include permanent roads (except as necessary to meet minimum
requirements for administration of the area, including measures required for emergencies
involving human health and safety), temporary roads, motor vehicles, motorized equipment,
motorboats, landing of aircraft, any form of mechanical transport, and structures (16 United States
Code [U.S.C.] 1121 [note], 1131-1136).
In furtherance of the purpose of the Wilderness Act of 1964, the Arizona Desert Wilderness Act of
1990 was established to provide for the designation of certain public lands as wilderness in the
state of Arizona (Public Law 88-577, found in 16 U.S.C. 1131-1136). There are no designated
wilderness areas within the project corridor. However, most of OPCNM beginning 150 feet north
of South Puerto Blanco Road is designated as Wilderness.
3.6

PROTECTED SPECIES AND CRITICAL HABITATS

3.6.1

Federal

An in-depth discussion of this resource was presented in the 2003 NPS Final EA and is
incorporated herein by reference (NPS 2003). Within Pima County, 13 species are listed as
Federally endangered, two are Federally threatened, one has been proposed for endangered
status and three for candidate species (Table 3-1). Not all of these species occur within the
vicinity of the project corridor; however, several have the potential to occur within or near the
project corridor. These include the lesser long-nosed bat, Sonoran pronghorn and the Acuna
cactus (Echinomastus erectocentrus var. acuñensis).

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Table 3-1. Federally Listed and Proposed Species Potentially Occurring Within Pima
County, Arizona
Common/Scientific Name

Federal/State
Status

Yellow-billed cuckoo
(Coccyzus americanus)

Candidate

Masked bobwhite
(Colinus virginianus ridgewayi)

Endangered

Southwestern willow
flycatcher
(Empidonax traillii extimus)
California brown pelican
(Pelecanus occidentalis
californicus)

Endangered
Endangered

Mexican spotted owl
(Strix occidentalis lucida)

Threatened

Sonoran pronghorn
(Antilocapra americana
sonoriensis)

Endangered

Ocelot
(Leopardus pardalis)
Lesser long-nosed bat
(Leptonycteris curasoae
yerbabuenae)

Endangered
Endangered

Jaguar
(Panthera onca)

Endangered

Sonoyta mud turtle
(Kinosternon sonoriense
longifemorale)

Candidate

Chiricahua leopard frog
(Rana chiricahuensis)

Threatened

Quitobaquito pupfish
(Cyprinodon macularius)

Endangered

Gila chub
(Gila intermedia)

Proposed
Endangered

Gila topminnow
(Poeciliopsis occidentalis
occindentalis)
Kearney blue star
(Amsonia kearneyana)
Pima pineapple cactus
(Coryphantha scheeri var.
robustispina)

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Endangered
Endangered

Endangered

Habitat

Potential to Occur within
or near Project Corridor

Large blocks of riparian woods.

No – No suitable habitat.

Desert grasslands with diversity
of dense native grasses, forbs,
and brush.
Cottonwood/willow and tamarisk
vegetation communities along
river and streams.
Coastal lands and islands, also
found around lakes and rivers
inland.
Nests in canyons and dense
forests with multi-layered foliage
structure.
Broad intermountain alluvial
valleys with creosote-bursage
and palo verde-mixed cacti
associations. Current distribution
known to occur on the CPNWR.
Dense, thorny chaparral
communities and cedar breaks.
Desertscrub habitat with agave
and columnar cacti present as
food plants.
Found in Sonoran desertscrub
up through subalpine conifer
forest.
Occurs in pond and streams;
however, it is restricted to
Quitobaquito Springs and nearby
stream habitat.
Streams, rivers, ponds,
backwaters, and stock tanks that
are mostly free from exotic
species at elevations ranging
from 1,200 to 4,000 feet.

No – Presently only known
to occur on Buenos Aires
NWR.

Shallow springs, small streams,
and marshes. Tolerant of saline
and warm water.
Pools, springs, cienegas, and
streams within the Gila River
system.
Small streams, springs, and
cienegas within the Gila River
system.
West-facing drainages in the
Baboquivari mountains.
Ridges in semi-desert grassland
and alluvial fans in Sonoran
desertscrub with elevation
ranges from approximately 2,300
to 5,000 feet.

3-6

No – No suitable habitat.
No – No suitable habitat.
No – No suitable habitat.

Yes- Species present on
CPNWR and OPCNM.
No – No suitable habitat.
Yes – Potential foraging
habitat present.
No – Extirpated from the
area.
No – Known to occur at
Quitobaquito Springs, but
outside of project corridor.

No – No suitable habitat.
No – Critical Habitat
designated within the
OPCNM at Quitobaquito
Springs and Pond, but
outside of the project
corridor.
No – Known populations
occur within the Gila River
drainage.
No – Known populations
occur within the Gila River
drainage.
No –Project corridor west
of Baboquivari Mountains.
No – Known populations
occur in east Pima County
at high elevations.

Final

Table 3-1, continued

Federal/State
Status

Common/Scientific Name
Nichol Turk’s head cactus
(Echinocactus horizonthalonius
var. nicholii)
Huachuca water umbel
(Liaeopsis schaffneriana var.
recurva)
Acuña cactus
(Sclerocactus erectocentrus
Synonym: Echinomastus
erectocentrus var. acunensis)

Habitat

Endangered

Unshaded microsites in Sonoran
desertscrub on dissected
limestone mountains.

Endangered

Cienegas, perennial low gradient
streams, wetlands.

Candidate

Acuña cacti are found on granite
substrates on rounded small hills
at elevations ranging from 1,3002,000 feet.

Potential to Occur within
or near Project Corridor
No – Known populations
occur in east Pima and
south Pinal counties.
No – Known populations
found in San Pedro River
Basin.
Yes – Potential to occur,
known populations are
located on OPCNM
approximately 8 miles
north of the U.S.-Mexico
border.

Source: USFWS 2007.

3.6.1.1 Sonoran Pronghorn
The Sonoran pronghorn was listed as Federally endangered on March 11, 1967 (32 Federal
Register [FR] 4001), and is currently recognized as one of five subspecies of pronghorn
(USFWS 1998). Sonoran pronghorn range from the plains of central and western Sonora,
Mexico north to southwestern Arizona (USFWS 2003). In Arizona, Sonoran pronghorn occur on
the CPNWR, the BMGR, and OPCNM, from State Route 85 west to the Cabeza Prieta
Mountains and from the vicinity of the Wellton-Mohawk Canal south to the U.S.-Mexico border
(Figure 3-1). Although, the Sonoran pronghorn is known to inhabit the OPCNM west of State
Route 85, the likelihood of encountering a Sonoran pronghorn within the project corridor is
limited because Mexico Highway 2 is near the project corridor, the existing barbed wire fence,
and human activity near Sonoyta, Mexico. All of these elements are considered an impediment
to pronghorn movement (NPS 2003).

3.6.1.2 Lesser Long-nosed Bat
The lesser long-nosed bat was listed as endangered on September 30, 1988 (53 FR 38456).
Lesser long-nosed bats are a nectar, pollen, and fruit eating species that migrates into southern
New Mexico and Arizona seasonally from Mexico (Arizona Game and Fish Department [AGFD]
2003). Lesser long-nosed bats migrate starting in early April, apparently following the flowering of
columnar cacti and desert agave (Agave deserti simplex), returning to Mexico during September
(USFWS 1995). A total of 206 saguaro and 295 organ pipe cacti were observed within the survey
corridor during the field surveys. It should be noted that over 85 percent of the columnar cacti
observed within the project corridor were located within the 0.65 miles across Sonoyta Hill.

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O

3-8

0

0

6

6

12
12

18
18

24
Kilometers

Sonoran Pronghorn Range

NS

Source: UGSG 1:100,000 El Centro quadrangle
USFWS 2003

μ

NAL

M

1:750,000

K CA

P
TA

Proposed Action Alternative

TO
WE L L

HAW
N-MO

C

E
EZ
AB
E
RI
I
TA
UN

2

ORGAN PIPE
NATIONAL
MONUMENT

Figure 3-1: Sonoran Pronghorn Range within Project Corridor

24
Miles

CABEZA PRIETA NWR

BARRY M GOLDWATER RANGE

8

§
¦
¨

85
¬
«

LUKEVILLE POE

Organ Pipe Cactus
National Monument

Why

Lukeville

85
V
U

Ajo

November 2007

Pisinemo

86
V
U

The lesser long-nosed bat is found during the summer within desert grasslands and scrublands.
The lesser long-nosed bat spends the day in caves and tunnels and forages at night upon plant
nectar and pollen. This bat is an important pollinator of agave, and organ pipe and saguaro
cacti (AGFD 2003). Roosting occurs in caves, abandoned buildings, and mines, which are
usually located at the base of mountains where food sources are present (AGFD 2003). The
lesser long-nosed bat is a seasonal resident of the OPCNM. Roosting sites are located in the
OPCNM, but no known roosting sites occur within the project corridor (NPS 2003). The closest
location of a known maternity colony to the project corridor would be approximately 15 miles
(NPS 2003).

3.6.1.3 Acuña Cactus
The candidate status of Acuña cactus was last reviewed on May 11, 2005 (70 FR 24870). Seven
populations of Acuña cactus are currently known to exist (Baiza 2007). The species is restricted
to well drained knolls and gravel ridges between major washes on substrates, including granite
hills and flats and bright red to white andesite, occurring from 1,300 to 2,000 feet in elevation
(AGFD 2004). The species requires insect vectors for pollination, with polylectic bee species
being the primary agent (AGFD 2004).

Dispersal occurs primarily through gravity, and

secondarily by wind, rain, and small insects.
As a candidate species, the Acuña cactus is not Federally protected, but is protected by the
Arizona’s Native Plant Law. Consideration is given to candidate species because of the potential
for their listing during project activities, which could require USFWS Section 7 consultation.
Although the Acuña cactus is known to inhabit the OPCNM, the known population is outside of the
project corridor (approximately 8 miles north of U.S.-Mexico border) and no specimens were
found within the project corridor during recent field surveys.
3.6.2

State

Suitable habitat for state sensitive species exists within the project corridor. All of the faunal
species listed in Table 3-1 have a state-sensitive designation of Wildlife of Special Concern
(WSC). State protected species (i.e., WSC) potentially found in the project corridor that are not
Federally protected include the Great Plains narrow mouthed toad (Gastrophyne olivacea),
cactus ferruginous pygmy-owl (Glaucidium brasilianum cactorum), Sonoran desert tortoise
(Gopherus agassizii), California leaf-nosed bat (Macrotus californicus), Mexican rosy boa
(Charina trivirgata trivirgata), and tropical kingbird (Tyrannus melancholicus). The Sonoran

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desert tortoise and the Mexican rosy boa have the potential to exist near Sonoyta Hill within the
project corridor. A complete list of state and Federal protected species for Pima County is
included in Appendix B.
3.6.3

Critical Habitat

The Quitobaquito pupfish (Cyprinodon macularius) is the only species near the project corridor
which has designated critical habitat. The critical habitat includes the Quitobaquito Springs and
pond, and a 100-foot riparian buffer (USFWS 1986). Although the Quitobaquito pupfish critical
habitat is located within the OPCNM, it is approximately 10.5 miles west of the project corridor.
3.7

CULTURAL RESOURCES

The NHPA of 1966 establishes the Federal government’s policy to provide leadership in the
preservation of historic properties and to administer Federally owned or controlled historic
properties in a spirit of stewardship. Section 106 of the NHPA of 1966, as amended, requires
Federal agencies to identify and assess the effects of their undertakings on cultural properties
included in or eligible for inclusion in the National Register of Historic Places (NRHP), and to
afford the Advisory Council on Historic Preservation (ACHP) a reasonable opportunity to
comment on such undertakings. Federal agencies must consult with the appropriate state and
local officials, Indian tribes, applicants for Federal assistance, and members of the public and
consider their views and concerns about historic preservation issues. The ACHP is authorized
to promulgate such rules and regulations as it deems necessary to govern the implementation
of Section 106 in its entirety.

Those regulations are contained in the Code of Federal

Regulations as 36 CFR Part 800, “Protection of Historic Properties”.
Several other important pieces of legislation include the Archeological Resources Protection Act
(ARPA), the Native American Graves Protection and Repatriation Act (NAGPRA), along with EO
13007 and EO 13175. ARPA strengthened the permitting procedures required for conducting
archeological fieldwork on Federal lands, originally mandated by the Antiquities Act. It also
established more rigorous fines and penalties for unauthorized excavation on Federal land.
NAGPRA mandates Federal agencies to summarize, inventory, and repatriate cultural items in
the possession of or control of the Federal agency to lineal descendants or to culturally affiliated
Federally recognized Indian tribes. NAGPRA also requires that certain procedures be followed
when there is an intentional excavation of or an inadvertent discovery of human remains. EO

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13007 was issued on May 24, 1996 in order to facilitate the implementation of the American
Indian Religious Freedom Act of 1978. It specifically charges Federal agencies to: (1)
accommodate, to the extent practical, American Indian access to and use of sacred sites by
religious practitioners; (2) avoid adversely affecting the physical integrity of sacred sites; and (3)
to maintain the confidentiality of these sites. E.O. 13175 outlines the official U.S. government
policy on consultation and coordination with American tribal governments.

The order

emphasizes formal recognition of the American Indian Tribes’ status as…“domestic independent
nations” that have entered into treaties with the U.S. guaranteeing their right to self-government.
It stipulates that this consultation would be done on a “government to government basis.”
3.7.1

Cultural History

The archaeology of southern Arizona is relatively complex considering the various geographic
and related cultural features. The OPCNM lies within a cultural area known as the Western
Papaguería, which includes the region bounded by the Colorado River to the west, the Gila
River to the north, the TON to the east, and Puerto Peñasco, Sonora, Mexico to the south
(USFWS 2001). The cultural history of OPCNM can be divided into five periods:
Period
Preceramic
Ceramic
Early Historic
Late Historic
World War II and Cold War

Dates
10,000 B.C. to A.D. 200
A.D. 200 to 1500
A.D. 1540 to 1848
A.D. 1848-1945
A.D. 1945-1989

Source: USFWS 2001

3.7.2

Previous Investigation

A cultural resources survey was conducted in 2002 for the proposed construction of vehicle
barriers along the U.S.-Mexico Border with the OPCNM. The survey corridor consisted of a 100
foot survey corridor along the international border within the OPCNM. The survey identified
seven cultural resources that would be potentially impacted by the proposed vehicle barriers
(NPS 2003).
3.7.3

Current Investigation

A site records check and cultural resources survey was conducted for the construction footprint
of the Proposed Action Alternative. Three previously recorded historic objects, International
Boundary Monuments 166, 167, and 168 were relocated during the current surveys.

The

International Boundary Monuments are listed on the NRHP and are considered significant
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cultural resources. In addition, one previously recorded archaeological site, the Gachado Well
and Line Camp (AZ C:1:17[ASM]) was also relocated and mapped during the current survey.
This archaeological site is also listed on the NRHP and is considered a significant cultural
resource. It should be noted that the Gachado Well and Line Camp, however, are not located
within the 60-foot wide project corridor (Tuomey 2007).
3.8

AIR QUALITY

A detailed discussion of air quality conditions was presented in the 2003 NPS Final EA and is
incorporated herein by reference (NPS 2003). Pima County is classified as being in attainment
for all criteria pollutants under the National Ambient Air Quality Standards (NAAQS) (Pima
County Department of Environmental Quality [PCDEQ] 2007).
According to 40 CFR 51.853(b), Federal actions require a Conformity Determination for each
pollutant where the total of direct and indirect emissions in a non-attainment or maintenance
area caused by a Federal action would equal or exceed any of the rates in paragraphs 40 CFR
51.853(b)(1) or (2). If emissions from a Federal action do not exceed de minimis thresholds,
and if the Federal action is not considered a regionally significant action, it is exempt from
further conformity analysis. Therefore, because Pima County is in attainment for all criteria
pollutants and because any alternative chosen would not exceed de minimis thresholds, a
conformity analysis is not warranted (see Section 4.8.2).
3.9

WATER RESOURCES

A detailed discussion of this resource was presented in the 2003 NPS Final EA and is
incorporated herein by reference (NPS 2003). Surface waters on OPCNM are limited as water
availability varies seasonally with the majority of rainfall occurring in late summer. Section 404 of
the CWA of 1977 (PL 95-217) authorizes the Secretary of the Army, acting through the Chief of
Engineers, to issue permits for the discharge of dredged or fill material into waters of the U.S.,
including wetlands. Any area that meets these criteria is commonly classified as “Waters of the
U.S.” Waters of the U.S. are further defined as all other waters such as intrastate lakes, rivers,
streams, mudflats, sand flats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes,
natural ponds, or impoundments of waters, tributaries of waters, and territorial seas. Activities that
result in the dredging and/or filling of jurisdictional Waters of the U.S., including wetlands, are

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regulated under Section 404 of the CWA. There are 16 intermittent streams which cross the
project corridor; however, there are no perennial streams on OPCNM (NPS 2003). Wetlands are
sparse on OPCNM and are limited to those areas with perennial water flow such as Quitobaquito
Springs and Aquajito Springs. Both of these wetland areas are outside of the project corridor and
would not be impacted (NPS 2003).
The project corridor is within the Western Mexican Drainage Basin (WMDB), which covers
approximately 730 square miles in southern Arizona (INS 2001).

The WMDB is similar in

structure to the surrounding Basin and Range Province basins that are characterized by broad
alluvium-filled valleys dissected by elongated mountain ranges. The Arizona Department of Water
Resources (ADWR) estimated that in 1988 approximately 4.1 million acre-feet of groundwater
was stored at a depth of 1,200 feet below the land surface (ADWR 2005, INS 2001). The annual
recharge rate for the WMDB is 2,400 acre-feet per year (Leake 2005). In 1985, the ADWR
estimated approximately 220 acre-feet of water was withdrawn from the WMDB (ADWR 2005).
Since the recharge rate far exceeds the withdrawal rate, the WMDB currently provides ample
groundwater supply for the current users.
The Lower Gila River Basin is situated north of the WMDB and OPCNM, within this basin,
groundwater occurs in both floodplain and basin fill deposits. Streambed or floodplain deposits
(consisting of sand, gravel, cobbles, and boulders) range from approximately 10 ft thick in the
smaller drainages to as much as 110 ft thick in the Gila River floodplain (Babcock et al. 1947).
The basin fill deposits may be divided into three separate units; the upper sandy unit, a middle
fine-grained unit, and a lower coarse-grained unit (ADWR 2004). These units vary in thickness
and may not be present at all locations. Groundwater recharge is from infiltration of rainfall
runoff and underflow from groundwater basins that are hydraulically up gradient (Weist 1965).
The groundwater for the construction of the proposed project would come from within this basin
and more than likely from the town of Why or Ajo, Arizona.

Because much of the land

surrounding the towns of Ajo and Why is undeveloped public land and the need for water in the
region is limited to the populated areas, the municipal wells often maintain high water levels
(Tibbits 2004).
Pursuant to the National Flood Insurance Act of 1968, as amended (42 USC 4001 et seq.), and
the Flood Disaster Protection Act of 1973 (P.L. 93-234, 87 Stat. 975), EO 11988, floodplain
management requires that each Federal agency take actions to reduce the risk of flood loss,

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minimize the impact of floods on human safety, health and welfare, and preserve the beneficial
values which floodplains serve. EO 11988 requires that agencies evaluate the potential effects
of actions within a floodplain and avoid floodplains unless the agency determines that there is
no practicable alternative. Where the only practicable alternative is to site in a floodplain, a
planning process is followed to ensure compliance with EO 11988. In summary, this process
includes the following steps:
•
•
•
•
•
•
•
•

determine whether or not the action is in the regulatory floodplain;
conduct early public notice;
identify and evaluate practicable alternatives, if any;
identify the impact of the action;
minimize the impact;
reevaluate alternatives;
present the findings and a public explanation; and
implement the action.

This process is further outlined on the FEMA’s Environmental Planning and Historic Preservation
Program Web site (FEMA 2006). As a planning tool, the NEPA process incorporates floodplain
management through analysis and public coordination, ensuring that the floodplain management
planning process is adhered to. In addition, floodplains are managed at the local municipal level
through the assistance and oversight of FEMA. According to FEMA Map Panel number
0007643050B, approximately 550 feet of the project corridor is located within the 100-year
floodplain. This area is located immediately west of the Lukeville POE.
3.10

SOCIOECONOMICS

The socioeconomic environment for the Region of Influence (ROI), Pima County, was described
in the 2003 Final EA and is herein incorporated by reference (NPS 2003). The population of
Pima County in 2006 was estimated at 902,720 (U.S. Census Bureau 2005). The 2005 racial
mix of Pima County was predominantly Caucasian (71.1 percent), followed by American Indians
and Alaskan Natives (3.2 percent), African Americans (2.9 percent) and Asian persons (2.4
percent), with the remaining 20.4 percent of the population reporting other races (U.S. Census
Bureau 2005). Persons of any race can claim Hispanic or Latino origin; 32 percent of the 2005
population of Pima County claim to be of Hispanic or Latino origin (U.S. Census Bureau 2005).
The total number of jobs in Pima County in 2005 was 486,165, an increase of 26 percent over
the number of jobs in 1995 (384,604; Bureau of Economic Analysis [BEA] 2005). The 2005
annual average unemployment rate for Pima County was 4.6 percent (Arizona Department of

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Final

Commerce 2005). This is lower than the 4.7 percent average annual unemployment rate for the
state of Arizona (Arizona Department of Commerce 2005).
In 2005, Pima County had a per capita personal income (PCPI) of $28,869. This PCPI ranked
2nd in the state of Arizona, and was 96 percent of the state average of $30,019, and 84 percent
of the National average of $34,471. Total personal income (TPI) for Pima County in 2005 was
$26.7 billion.
3.10.1 Environmental Justice
E.O. 12898 (Federal Actions to Address Environmental Justice in Minority and Low-Income
Populations) was signed in February 1994. This order was intended to direct Federal agencies
“…to make achieving environmental justice part of its mission by identifying and addressing…
disproportionately high and adverse human health or environmental effects of its programs,
policies, and activities on minority populations and low-income populations in the [U.S.]…” To
comply with the E.O., minority and poverty status in the vicinity of the project was examined to
determine if any minority and/or low-income communities would potentially be disproportionately
affected by implementation of the Proposed Action Alternative. Both low-income and minority
populations are prevalent within the ROI. No residential areas exist in or near the project
corridor in the U.S. However, developed areas (i.e., residential) are located adjacent to the
project corridor in Sonoyta, Mexico.
3.10.2 Protection of Children
E.O. 13045 requires each Federal agency “to identify and assess environmental health risks
and safety risks that may disproportionately affect children”, and “ensure that its policies,
programs, activities, and standards address disproportionate risks to children that result from
environmental health risks or safety risks”. This E.O. was prompted by the recognition that
children, still undergoing physiological growth and development, are more sensitive to adverse
environmental health and safety risks than adults. The potential for impacts to the health and
safety of children is greater where projects are located near residential areas. No residential
areas exist in or near the project corridor in the U.S. However, developed areas (i.e., residential)
are located adjacent to the project corridor in Sonoyta, Mexico.

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3.11

NOISE

Noise is generally described as unwanted sound, which is identified by either objective effects
(hearing loss, damage to structures, etc.) or subjective judgments (community annoyance). Sound
is represented on a logarithmic scale with a unit called the decibel (dB). Sound on the decibel
scale is referred to as a sound level. The threshold of human hearing is approximately 0 dB, and
the threshold of discomfort or pain is around 120 dB.
Sound levels are computed over a 24-hour period and adjusted for nighttime annoyances to
produce the day-night average sound level (DNL). DNL is the community noise measurement
recommended by the U.S. Environmental Protection Agency (EPA) and has been adopted by
most Federal agencies (EPA 1974). A-weighted decibels (dBA) are used to express the relative
loudness of sounds in air as perceived by the human ear (Generac Power Systems, Inc. 2004).
A-weighting is necessary to compare the effects of sounds on the human body, because the
human ear is less sensitive at low frequencies than at high frequencies. A DNL of 65 dBA is most
commonly used for noise planning purposes, and represents a compromise between community
impact and the need for activities like construction. Areas exposed to DNL above 65 dBA are
generally not considered suitable for residential use. A DNL of 55 dBA was identified by EPA as a
level below which there are effectively no adverse impacts (EPA 1974).
Noise levels surrounding the project corridor are variable depending on the time of day and
climatic conditions. The construction activities potentially causing elevated noise levels within the
project corridor would include diesel and gasoline powered generators, trucks, and construction
equipment.
Heavy duty trucks generate a noise level of approximately 90 dBA. Attenuation to 55 dBA occurs
at a distance of approximately 2,600 feet depending on climatic conditions, topography,
vegetation, and man-made barriers (Generac Power Systems, Inc. 2004). Noise levels for other
types of construction equipment range from the loudest, tractors and backhoes (70 to 95 dBA) to
pumps and generators (65 to 85 dBA) (Bugliarello et al. 1976). The Lukeville POE is a busy port
with continuous traffic during its hours of operation. Therefore, noise generated near the POE is
expected to be elevated due to the operation of the POE and associated traffic. The OPCNM and
its associated Wilderness Area as well as the residences in Mexico are considered sensitive noise
receptors and are located near the project corridor.

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3.12

AESTHETICS

Aesthetic resources consist of the natural and man-made landscape features that appear
indigenous to the area and give a particular environment its visual characteristics. The major
visual characteristic of southern Arizona lies in its vast areas of naturally occurring landscape,
tranquil dark skies, and scenic mountain ranges. The project corridor is located near Sonoyta,
Mexico and the town of Lukeville, Arizona (i.e., Lukeville POE). OPCNM and its associated
Wilderness Areas are located adjacent to the project corridor and are visited for recreational
purposes, natural settings, and aesthetic values. However, the project corridor currently has a
limited aesthetic value due to the disturbed nature of the project footprint, existing PVBs and
chain link fence, illegal trails, trash (Photograph 3-1), Sonoyta, Mexico (Photograph 3-2), and
Lukeville POE (Photograph 3-3).

Photograph 3-1. Trails and trash left by IAs near
Lukeville, Arizona POE.

Photograph 3-2. View of Sonoyta, Mexico
residential areas from U.S. Border near Lukeville,
Arizona.

Photograph 3-3. Lukeville, Arizona-Sonoyta,
Mexico POE.

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3.13

WASTE

3.13.1 Hazardous Waste
EPA’s mission is to protect humans and the environment and work to develop and enforce
regulations that implement environmental laws enacted by Congress (from such legislation as
the Resource Conservation and Recovery Act of 1976 and the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980). The EPA maintains a list of hazardous
waste sites, particularly waste storage/treatment facilities or former industrial manufacturing
sites in the U.S. The chemical contaminants released into the environment (air, soil or
groundwater) from hazardous waste sites may include heavy metals, organic compounds,
solvents and other chemicals. The potential adverse human health impact of hazardous waste
sites is a considerable source of concern to the general public, as well as government agencies
and health professionals.
EPA databases, Environmental and Compliance History Online and Envirofacts Data
Warehouse, were reviewed for the locations of hazardous waste sites within or near the
proposed project corridor (EPA 2007a, 2007b). According to both of these databases, no
hazardous waste sites are located near or within the project corridor.
3.13.2 Unregulated Solid Waste
Unregulated solid waste within OPCNM has become a severe problem in recent years due to
illegal vehicle and foot traffic.

According to the Ninth Report of the Good Neighbor

Environmental Board (GNEB) to the President and Congress of the U.S., the average IA
disposes of approximately 8 pounds of waste a day. This waste consists of backpacks, clothing,
blankets, water bottles, plastic sheeting, food, and other debris (GNEB 2006). Within the project
area these forms of unregulated solid waste are the most commonly observed.

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SECTION 4.0
ENVIRONMENTAL CONSEQUENCES

4.0

ENVIRONMENTAL CONSEQUENCES

In accordance with CEQ regulations (40 CFR § 1502.16), this section of the EA addresses
potential impacts to the affected environment within the project corridor for the two alternatives
outlined in Section 2 of this document.

An impact (consequence or effect) is defined as a

modification to the human or natural environment that would result from the implementation of an
action. The impacts can be either beneficial or adverse, and can be either directly related to the
action or indirectly caused by the action. The effects can be temporary, short-term, long-term or
permanent. For purposes of this EA, temporary effects are defined as those that would occur
during construction or immediately after construction; short-term impacts would last less than 3
years after completion of the action. Long-term impacts are defined as those that would last 3 to
10 years. Permanent impacts would indicate an irretrievable loss or alteration of resources.
Impacts can vary in degree or magnitude from a slightly noticeable change to a total change in the
environment.

The significance of the impacts presented in this EA is based upon existing

regulatory standards, scientific and environmental knowledge, and best professional opinions.
Significant impacts are those effects that would result in substantial changes to the environment
(as defined by 40 CFR 1500-08) and should receive the greatest attention in the decision making
process.
This EA describes the potential permanent impacts assuming that the entire 60-foot Roosevelt
Reservation and 150-foot project footprint over Sonoyta Hill would be disturbed.

It is also

assumed that within the construction footprint any impacts would be permanent. Therefore, the
permanent impacts described for the Proposed Action Alternative would total approximately 45
acres (12 acres within 150-foot wide footprint and 33 acres the within 60-foot wide footprint).
Other assumptions were also made in this EA regarding the primary pedestrian fence. It was
assumed that in order to build the road and fence would require a range of 5.2 to 11.4 acre-feet
(1.7 million gallons to 3.7 million gallons) of water for the concrete footer and dust suppression.
One acre-foot is equivalent to 325,000 gallons of water. The primary pedestrian fence would
require, as needed, maintenance activities to be performed by USBP that would be mostly
limited to minor patchwork repairs and standard maintenance operations. These maintenance
activities would not result in significant impacts to the natural or human environment.

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The following discussions describe and, where possible, quantify the potential effects of each
alternative on the resources within or near the project corridor. All impacts described below are
considered to be adverse unless stated otherwise.
4.1

LAND USE

4.1.1

Alternative 1: No Action Alternative

Under the No Action Alternative, no infrastructure proposed as part of this project would be
constructed.

Although land use would not change, IA pedestrian traffic on OPCNM would

continue and potentially increase with the implementation of other border enforcement activities
along the southwest border.
4.1.2

Alternative 2: Proposed Action Alternative

The majority of the project corridor is within the Roosevelt Reservation. However, some of the
project corridor (i.e., 7 acres) over Sonoyta Hill is not within the Roosevelt Reservation and would
be used for USBP infrastructure maintenance and enforcement operations. A Special Use Permit
articulating USBP’s use of the 7 acres would be obtained from the NPS prior to construction, since
the area would remain under NPS’s management. The use of 7 acres represents less than 0.002
percent of the total OPCNM.
Indirect impacts to land use could occur outside of the project corridor as IAs attempt to
circumvent the proposed infrastructure. These impacts cannot be quantified at this time because
IA patterns and migration routes are completely out of USBP’s control. However, the primary
pedestrian fence would act as a force multiplier and allow for USBP to deploy agents to areas
without pedestrian barriers. Therefore, potential adverse indirect impacts to land use would be
minimal. Indirect beneficial impacts to land use on OPCNM are expected as a result of decreased
illegal traffic within the project corridor. By reducing illegal traffic within and adjacent to the project
corridor, damage to OPCNM north of the project corridor would also be reduced or possibly
eliminated. OPCNM has identified that implementation of the Proposed Action Alternative might
allow OPCNM to re-open some areas east of Lukeville (i.e., Gachado Line Camp) to the public
that have been closed in the past due to IA activity (Kralovec 2007).

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Final

4.2

SOILS

4.2.1

Alternative 1: No Action Alternative

No ground disturbing activities would be conducted as a result of this alternative. Therefore, the
No Action Alternative would have no direct impacts, either beneficial or adverse, on the soils
within the project corridor. However, soils are currently indirectly impacted by illegal pedestrian
traffic on OPCNM. In the absence of the primary pedestrian fence, IA foot traffic would continue
and potentially increase, disturbing additional soils and causing soil erosion north of the project
corridor.
4.2.2

Alternative 2: Proposed Action Alternative

The Proposed Action Alternative would permanently impact approximately 45 acres of soils
within the project corridor through the construction of the primary pedestrian fence. About 17
acres of the total footprint are highly disturbed from the construction of the existing PVBs.
Although these impacts would be permanent, they would not be considered significant because
the impacts would primarily affect previously disturbed soils, and because of the vast amounts
of similar soil types adjacent to the project corridor. No impacts to prime farmlands would occur.
As a result of this alternative, the volume of illegal pedestrian traffic would be expected to
decrease and, consequently, would result in long-term indirect beneficial impacts to soils north of
the project corridor. Indirect adverse effects to soils could occur in adjacent areas where the
border infrastructure proposed under this alternative is not employed, as IAs try to circumvent the
improved areas to avoid detection.
A Stormwater Pollution Prevention Plan (SWPPP) and Notice of Intent (NOI) under the CWA’s
National Pollutant Discharge Elimination System (NPDES) would be required for all construction
sites greater than 1 acre (33 U.S.C. §1342). These and other mitigation measures proposed to
reduce or minimize erosion and ensure the hydrology of the project corridor is not permanently
altered are discussed in Section 6.0.

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Final

4.3

BIOLOGICAL RESOURCES

4.3.1

Vegetation Communities

4.3.1.1 Alternative 1: No Action Alternative
There would be no direct impacts to the project corridor’s vegetation communities as no
construction would occur. Adverse, long term impacts to vegetation and vegetation communities
would continue to occur from the continued damage caused by IA foot traffic on OPCNM. The No
Action Alternative would not increase deterrence of illegal entry nor expand the window of
opportunity for USBP agents to detect and respond to illegal entry attempts. Implementation of
the No Action Alternative would result in continued indirect adverse impacts to vegetation
communities from illegal traffic.

4.3.1.2 Alternative 2: Proposed Action Alternative
Implementation of the Proposed Action Alternative would result in the permanent loss of
approximately 28 acres within the project corridor. The remaining 17 acres within the project
corridor has no vegetation due to past construction and other human disturbances.

The

vegetation that does occur consists of locally and regionally common species; therefore, negligible
effects would occur to the region’s vegetation. Erosion within the disturbed areas would occur but
would be minimized by implementing pre- and post-construction BMPs identified in the SWPPP.
The proposed primary pedestrian fence and road would be designed and constructed in a manner
that would not alter drainage patterns; thus, increased downstream erosion or sedimentation,
which could affect vegetation communities, would not be expected.
Beneficial indirect impacts, such as a reduction of native vegetation being damaged from illegal
activities and consequent USBP enforcement activities, would occur as IAs and smuggling
activities are reduced or potentially eliminated within the area. Conversely, areas outside of the
project corridor could be indirectly impacted as IAs attempt to avoid detection and circumvent
the proposed infrastructure.

These impacts cannot be quantified at this time because IA

patterns and migration routes are completely out of USBP’s control. However, the primary
pedestrian fence would act as a force multiplier and allow USBP to deploy agents to areas
without pedestrian barriers, therefore, minimizing potential adverse indirect impacts.

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Final

4.3.2

Wildlife

4.3.2.1 Alternative 1: No Action Alternative
No impacts to fish and wildlife resources would occur as a result of the implementation of the No
Action Alternative because no construction activities would occur. However, indirect adverse
impacts to wildlife from continued illegal pedestrian traffic degrading habitat would occur and
could potentially increase.

4.3.2.2 Alternative 2: Proposed Action Alternative
Although approximately 45 acres would be permanently impacted from the Proposed Action
Alternative, these impacts would be considered negligible, since much of the project corridor (17
acres) has been previously disturbed, and the remainder has limited and somewhat disturbed
vegetation. The Proposed Action Alternative would not have direct impacts to fish or other aquatic
species, because the proposed construction activities would not take place in naturally flowing or
standing water. Mitigation measures would be implemented for construction in or near washes as
stated in Section 6.0 and follow the measures described in the project’s SWPPP to reduce
potential impacts to riparian areas from erosion or sedimentation.
Mobile animals (e.g., birds) would escape to areas of similar habitat, while other slow or sedentary
species of reptiles, amphibians, and small mammals could potentially be lost. As a result, direct
minor adverse impacts to wildlife species in the vicinity of the project corridor are expected.
Although some animals may be lost, this alternative would not result in any substantial reduction
of the breeding opportunities for birds and other animals on a regional scale due to the tens of
thousands of acres of suitable, similar habitat adjacent to the project corridor.

Additionally,

mitigation measures would be implemented to ensure that no “take” of migratory birds occurs if
this alternative is implemented, in accordance with the Migratory Bird Treaty Act (MBTA).
Although the primary pedestrian fence could preclude transboundary migration patterns of
animals, especially larger mammals (e.g., mule deer [Odocoileus hemionus]), and thus
fragmenting habitat within the project corridor, these impacts would be considered minimal.
Habitat fragmentation typically affects species with small population sizes or that are dependent
upon migration to obtain spatially or temporally limited resources (Gilpin and Hanski, 1991). The
primary pedestrian fence would be designed and constructed in the washes to allow proper
conveyance of flood flows. It is expected that these designs would also allow the transboundary
migration of reptiles, amphibians, and small mammals, which would reduce the fragmentation

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effects. Wildlife would also still be able to migrate across the U.S.-Mexico border either to the east
or west of the project footprint terminus. In addition, the species located within the project corridor
are regionally common in both the U.S. and Mexico. Therefore, no significant adverse effects are
anticipated to the region’s wildlife population.
Indirect adverse impacts to wildlife habitat adjacent to the project corridor could occur as illegal
pedestrian traffic attempts to circumvent the proposed infrastructure. It is possible for IAs to
attempt illegal entry outside of the project corridor. However, the primary pedestrian fence would
act as a force multiplier and allow USBP to deploy agents to areas without pedestrian barriers,
minimizing potential adverse indirect impacts. Beneficial indirect impacts would be expected
from the protection afforded to areas to the north of the project corridor due to the
implementation of the Proposed Action Alternative.
4.3.3

Non-native and invasive species

4.3.3.1 Alternative 1: No Action Alternative
No impacts to non-native and invasive plants are expected as a result of the No Action Alternative
because no construction activities would occur. However, indirect adverse impacts, such as the
spread of non-native or invasive plants, could occur as a result of continued illegal pedestrian
traffic.

4.3.3.2 Alternative 2: Proposed Action Alternative
Disturbance of 45 acres (total) of soils during the construction activities would result in favorable
conditions for the establishment of non-native and invasive species. Disturbances would occur
in vegetated areas that would create dispersal corridors for invasive species. However, because
the project corridor would be patrolled and maintained by NPS and USBP (limiting potential for
growth of new sprouts) and would be monitored for the spread of invasive species, potential
impacts would not be considered significant. With the exception of Sonoyta Hill, some of the
project corridor has been previously disturbed from the construction of the existing PVBs.
Regardless, the establishment of invasive species within disturbed areas would be minimized
through mitigation measures mentioned above and as described later in Section 6.0.

The

Proposed Action Alternative would also serve as a barrier to the spread of non-native and
invasive plants, as many invasive plant propagules are transported into the U.S. on clothing of
IAs (INS 2002).

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Final

4.4

UNIQUE AND SENSITIVE AREAS

4.4.1

Alternative 1: No Action Alternative

No impacts to unique and sensitive areas would result from the implementation of the No Action
Alternative, as no construction would occur. However, indirect adverse impacts to unique and
sensitive areas due to continued illegal pedestrian traffic would occur and could potentially
increase.
4.4.2

Alternative 2: Proposed Action Alternative

Noise increases due to construction activities would be temporary; therefore, no long-term
significant impacts to unique and sensitive areas, as a result of increases in ambient noise levels,
would occur. The construction crews and equipment would access the project corridor along the
border road primarily within the Roosevelt Reservation, limiting visual and noise impacts to the
OPCNM. However, the use of South Puerto Blanco Road would be required to access the project
corridor on the western face of Sonoyta Hill. A Special Use Permit from NPS would be needed for
construction to access areas outside of the Roosevelt Reservation. This permit would be obtained
prior to construction activities. Temporary impacts to aesthetics would be expected for the
duration of the construction activities; however, these would be eliminated upon completion of this
alternative. Permanent impacts to aesthetics would also be expected due to the additional
infrastructure. However, these impacts would occur primarily within previously disturbed areas
and mitigation measures (i.e., using non-reflective materials) would be implemented to ensure any
impacts would be less than significant.
Furthermore, approximately 7 acres of unique and sensitive area (i.e., OPCNM) would be directly
impacted. This area is located on Sonoyta Hill along the western terminus of the project corridor.
Although OPCNM would be adversely impacted, these impacts would not be considered
significant as the indirect beneficial impacts from long-term protection of the remaining portions of
OPCNM would be expected to outweigh the direct impacts.
The proposed infrastructure would have indirect beneficial impacts to unique and sensitive areas
by reducing the frequency of illegal pedestrian traffic on OPCNM and subsequent creation of trails
and disposal of trash. Furthermore, long-term protection of OPCNM resources such as natural
vegetation, landscapes, and cultural sites would be expected under the Proposed Action
Alternative. Indirect adverse impacts such as a decline in visitor attendance may occur during

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construction activities; however, once the construction activities are complete, OPCNM would be
afforded better protection and a safer environment. Thus, in the long-term, visitor experiences
would be potentially enhanced (see Section 4.1.2). Other indirect adverse impacts to unique and
sensitive areas outside of the project corridor could occur if IAs chooses to circumvent the
proposed primary pedestrian fence. However, the primary pedestrian fence would act as a force
multiplier and allow USBP to deploy agents to areas without pedestrian barriers; therefore,
potential adverse indirect impacts would be minimized.
4.5

WILDERNESS

4.5.1

Alternative 1: No Action Alternative

No impacts to Wilderness Areas would occur from the implementation of the No Action
Alternative, as no construction would occur. However, indirect adverse impacts to Wilderness
Areas north and west of the project corridor could occur, since illegal pedestrian traffic would
continue to occur and could potentially increase.
4.5.2

Alternative 2: Proposed Action Alternative

Wilderness Areas as defined in the Wilderness Act of 1964 are lands in an area where the earth
and its community of life are untrammeled by man. The Proposed Action Alternative would not
directly impact any areas designated as Wilderness Area. However, noise associated with
construction equipment and construction activities would adversely affect Wilderness Area
characteristics.

These impacts would be temporary because noise levels near the OPCNM

Wilderness would return to preconstruction levels upon completion of construction activities.
Additionally, aesthetic qualities inherent to Wilderness Areas would be adversely impacted by the
sight of the primary pedestrian fence within the viewshed. Two schematic representations of how
the fence would appear from South Puerto Blanco road (near the OPCNM Wilderness) are
presented in Exhibit 4-1 and 4-2. Additionally, as shown previously in Photographs 3-1 through 33, the area along the border contains a lot of development, litter, trails, and other types of
disturbances. The primary pedestrian fence would reduce the amount of IA-associated litter and
trails and screen the surrounding development from park visitors. Therefore, the adverse impacts
of the primary pedestrian fence, when compared to the No Action Alternative and the long-term
benefits of the primary pedestrian fence, would be considered insignificant.

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Exhibit 4-1. Schematic Representation of View from South Puerto Blanco Road Facing
Southwest

Exhibit 4-2. Schematic Representation of View from South Puerto Blanco Road Facing
Southeast

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There is a potential for areas adjacent to the project corridor to experience an increase in illegal
foot traffic with the implementation of this alternative. All or none of the illegal foot traffic could
shift to either east or west of the project corridor and potentially into designated Wilderness Areas.
However, the Proposed Action Alternative would allow USBP to deploy agents, as needed, to
other areas that are unprotected, which would reduce IA traffic impacts to Wilderness Areas near
the project corridor. Therefore, no significant direct or indirect impacts to Wilderness Areas would
be expected upon implementation of the Proposed Action Alternative.
4.6

PROTECTED SPECIES AND CRITICAL HABITAT

4.6.1

Alternative 1: No Action Alternative

The No Action Alternative would not directly impact any protected species as no construction
activities would occur. However, indirect adverse impacts to protected species, such as habitat
degradation as a result of continued illegal pedestrian traffic, would occur and could potentially
increase.
4.6.2

Alternative 2: Proposed Action Alternative

The potential impacts to the Sonoran pronghorn associated with the Proposed Action
Alternative would be similar to those discussed in the 2003 NPS Final EA and are incorporated
herein by reference (NPS 2003). As seen on Figure 3-1, the Sonoran pronghorn range is not
within the project corridor. Additionally, the project corridor is located along the U.S.-Mexico
border (which is rarely visited by the pronghorn), within 2.1 miles of the Lukeville POE
(pronghorn are very reclusive and do not like human interaction), and contains previously
disturbed habitat. Although no direct impacts would occur to the pronghorn, there is the potential
for indirect adverse impacts if IA traffic shifts west of the proposed infrastructure. Therefore,
through consultation with USFWS, CBP and USBP has determined that this alternative would
adversely effect the Sonoran pronghorn. CBP and USBP would implement conservation
measures, identified during the Section 7 consultation process, to offset these impacts. Some
conservation measures that have been identified and would be implemented include:
1.

During construction USBP would conduct daily observations of project region as
close to dawn as possible to determine if Sonoran pronghorn are within 0.62 mile
of project activities. No project work will begin until pronghorn move on their own
volition to a distance greater than 0.62 mile from the activities. This measure
would be relevant for those activities only on the western slope of Sonoyta Hill,
where there is a greater potential for pronghorn to occur.

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2.

The number of vehicles traveling to and from the project site for construction
purposes and the number of trips per day would be minimized to reduce the
likelihood of disturbing pronghorn in the area or injuring an animal on the road.
The use of vehicle convoys, multi-passenger vehicles, and other methods are
appropriate to project construction.

3.

CBP will provide assistance to annually fill one supplemental water for Sonoran
pronghorn on OPCNM per the CBP programmatic mitigation agreement with
USFWS.

The project corridor is not located near any known bat roosting sites, and therefore, would not
affect any roost sites, including maternity roosts. Almost all of the Sonoran Desert is considered
foraging habitat for the lesser long-nosed bat and OPCNM consist of over 330,300 acres of
Sonoran Desert. The permanent disturbance of 28 acres of foraging habitat would amount to
the loss of less than 0.0006 percent of foraging habitat within the OPCNM. However, USBP
and USFWS have determined that this loss would constitute an adverse impact on the lesser
long-nose bat. Conservation measures developed through the Section 7 consultation process
would be implemented by USBP to offset these impacts. For example, saguaro and other
columnar cacti, which are main food sources for the lesser long-nosed bats, that are located
within the project footprint would be removed, avoided, relocated, or replaced as part of the
construction activities. Specifications regarding the size of columnar cacti to be relocated or
replaced are presented in Section 6.0. Examples of other conservation measures that have
been identified and would be implemented include the following:
1.

Clearly demarcate the construction footprint to ensure construction contractors
do not expand the disturbance area.

2.

Salvage of lesser-long nosed bat food plants from areas to be disturbed by
project activities as described in the salvage plan.

3.

Complete a restoration plan for various illegal trails and roads to compensate for
creation or improvement of roads needed for the fence project (in addition to
other concerns, this will address the control of non-native, invasive plant species)
within six months of issuance of the Biological Opinion.

Although no Sonoran desert tortoises or Mexican rosy boas were observed within the project
corridor, the potential exists for them to occur near Sonoyta Hill. Wildlife strikes could be caused
by construction vehicles or USBP patrol vehicles during project construction, maintenance
activities, and during future USBP operations. However, the likelihood of these strikes are low
because of the ability of most wildlife species to escape to surrounding habitat and the relatively
low vehicle speed of construction and USBP patrol vehicles, especially in this rugged terrain.
Due to the beneficial impacts of a reduction of habitat degradation north of the project corridor

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combined with mitigation measures discussed in Section 6, these potential impacts to these two
species are considered insignificant.
Additionally, the cactus ferruginous-pygmy owl has the potential to exist in the project corridor.
However, the habitat in the project corridor is extremely limited and classified as ranging from
poor to moderate with the exception of the western slope of Sonoyta Hill (NPS 2003).
Therefore, due to the previously disturbed nature of some of the project corridor in conjunction
with the limited quality habitat available, CBP has determined that the Proposed Action
Alternative would not adversely affect the cactus ferruginous pygmy owl.
Indirect adverse impacts to potentially suitable habitat for protected species along the southwest
border could occur due to IAs shifting their activities in order to avoid apprehension. It is
impossible, however, for USBP to determine how much of the illegal pedestrian traffic currently
entering the project corridor would shift either to the east, west, or be eliminated completely.
The implementation of the Proposed Action Alternative would reduce or eliminate illegal foot
traffic north of the primary pedestrian fence within the project corridor, protecting habitat that
could otherwise be disturbed and permanently degraded.

Further, because the primary

pedestrian fence would act as a force multiplier, USBP would be able to deploy agents to those
areas without primary pedestrian fence, minimizing potential indirect impacts to protected
species habitat.
4.6.3

Critical habitat

No critical habitat exists near or within the project corridor; therefore, no direct impacts would be
expected. Indirect adverse impacts could occur to areas outside of the project corridor (i.e.,
Quitobaquito Springs); however, these potential impacts are outside of the USBP’s control. IA
movement, if any, to avoid the proposed infrastructure would be totally at the IAs discretion.
Because the primary pedestrian fence would act as a force multiplier, USBP would be able to
deploy agents to those areas lacking primary pedestrian fence and therefore, minimize potential
indirect impacts.
Water would be trucked into the project corridor from sources located north of the OPCNM.
These sources would be located within a completely different watershed and basin than
Quitobaquito Springs. Therefore, the use of groundwater for the implementation of this project is

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not expected to cause a deficit of water availability nor a drop in hydrostatic pressure for
Quitobaquito Springs.
4.7

CULTURAL RESOURCES

4.7.1

Alternative 1: No Action Alternative

No impacts to cultural resources are expected, as no construction activities would occur.
However, indirect adverse impacts to cultural resources as a result of continued IA pedestrian
traffic disturbing cultural resources north of the project corridor could occur, and could potentially
increase.
4.7.2

Alternative 2: Proposed Action Alternative

Three historic objects, International Boundary Monument 166, 167, and 168 are located within the
project corridor and could be potentially affected by the Proposed Action Alternative. The historic
objects are listed on the NRHP and are considered significant cultural resources. Mitigation
measures to avoid adverse impacts to the cultural resources are outlined in Section 6 of this
document. These measures, as well as other potential mitigation measures developed through
consultation with the Arizona State Historic Preservation Officer (SHPO), would assure that no
adverse impacts would occur to these cultural resources. SHPO concurrence with USBP’s
determination of “no affect to historic properties” is included in Appendix C.
As a result, the Proposed Action Alternative would not result in significant impacts on cultural
resources provided mitigation measures, which will be identified through the Section 106 process,
are properly implemented.
4.8

AIR QUALITY

4.8.1

Alternative 1: No Action Alternative

No impacts to air quality are expected as no construction activities would occur. However, indirect
adverse impacts to air quality from illegal pedestrian traffic and subsequent USBP enforcement
activities would occur, and could potentially increase.

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4.8.2

Alternative 2: Proposed Action Alternative

Fugitive dust or PM-10 from soil disturbance, and emissions associated with construction
equipment engines, are expected to create temporary, minor increases in air pollution in the
project corridor. Due to the short duration of the construction project, any increases or impacts
on ambient air quality are expected to be short-term and below levels that would cause Pima
County to be in non-attainment for air quality standards.
A model was used to estimate the total air emissions from the new construction activities.
Calculations were made for standard construction equipment such as drilling rigs, hole cleaners,
generators, cement trucks, backhoes, cranes, and bulldozers using emission factors from EPA
approved emission model NONROAD6.2. Model results for air emissions are presented in
Appendix D. Fugitive dust emissions were calculated using emission factors from Mid-Atlantic
Regional Air Management Association (MARAMA 2006) for the primary pedestrian fence
construction.
Assumptions were made regarding the type of equipment, duration of the project, and the
number of hours per day each type of equipment would be used. The assumptions, emission
factors, and resulting calculations are presented in Appendix D.
emissions are presented in Table 4-1.

A summary of the total

As Pima County is in attainment for all air quality

standards, an air conformity analysis is not required.
Table 4-1. Total Air Emissions (tons/year) from Construction Activities
Pollutant

Total (tons/year)

Carbon Monoxide
Volatile Organic Compounds
Nitrogen Oxides
Particulate Matter <10 microns
Particulate Matter < 2.5 microns
Sulfur Dioxide

23.49
5.28
43.93
32.92
9.52
5.38

Source: 40 CFR 51.853 and Gulf South Research Corporation (GSRC) 2007

Impacts from combustible air emissions due to everyday USBP traffic are expected to be the
same after the primary pedestrian fence is built as they are currently. Construction workers
would temporarily increase the combustible emissions in the air shed during their commute to
and from work. Supplies would have to be delivered to the site by large delivery trucks. The

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emissions from supply trucks and workers commuting to work were included in the air emission
analysis (Appendix D) and in the totals presented in Table 4-1.
During the construction of the proposed project, proper maintenance of all vehicles and other
construction equipment shall be implemented to ensure that emissions are within the design
standards of all construction equipment. Dust suppression methods (e.g., watering of soils)
shall be implemented to minimize fugitive dust emissions. Such measures would further ensure
that air emissions generated by the Proposed Action Alternative would be temporary and would
not significantly impair air quality in the region.
Indirect impacts to air quality due to the shifting of illegal traffic in order to avoid the proposed
infrastructure is possible; however, it is unknown where IAs would choose to breach the U.S.Mexico border. Therefore, it is impossible for USBP to determine how much of the illegal traffic
currently entering the project corridor would shift either to the west or be eliminated completely.
4.9

WATER RESOURCES

4.9.1

Alternative 1: No Action Alternative

No impacts to water resources as a result of the No Action Alternative are expected because no
construction activities would occur.
4.9.2

Alternative 2: Proposed Action Alternative

No wetlands would be either directly or indirectly impacted as a result of this alternative as none
exist within the project corridor. A total of 16 intermittent streams cross the project corridor. All
appropriate CWA Section 404 Permits from the U.S. Army Corps of Engineers (USACE) Los
Angeles District Regulatory Branch, as well as Section 401 Water Quality Certifications from the
Arizona Department of Environmental Quality, would be obtained prior to any fill material being
placed in potential jurisdictional waters of the U.S.

As mentioned previously, the primary

pedestrian fence and road would be designed and constructed in a manner that would not alter
drainage patterns or exacerbate erosion and sedimentation problems. Pre- and post-construction
BMPs would also be implemented to further reduce the potential for erosion and sedimentation.
Some of these measures are described in Section 6.0. Furthermore, as mentioned in Section 2.2,
USBP would be responsible for maintaining the primary pedestrian fence an assuring that any

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debris accumulated along the primary pedestrian fence during rain events is quickly removed to
prevent backwater flooding.
Although the project corridor traverses the 100-year floodplain, no adverse impacts are expected.
The design of the primary pedestrian fence will incorporate features to ensure that flows and flood
elevations within the floodplain are not adversely modified, both locally and regionally. CBP has
determined that there is no other practicable alternative to constructing sections of the fence
within the floodplain, as the border bisects the floodplain and the proposed fence must be located
on the border. Therefore, the Proposed Action Alternative would not contradict E.O. 11988 nor
create significant impacts to floodplains.
It is estimated that a range of 5.2 to 11.4 acre-feet of water would be required for dust
suppression and construction activities. Water would be obtained from a source north of the
OPCNM (e.g., Why, Ajo, or Gila Bend) and be trucked in to the project corridor. The use of water
from these sources would not create a deficit either locally or regionally. Therefore, no significant
impacts to groundwater within the project corridor would be expected.
During construction activities, degradation of water quality as a result of sediment transported by
stormwater within any of the washes located within the project corridor would be minimized by
implementing the SWPPP and best management practices (BMPs). Equipment required for the
construction activities would not be staged or stored within 100 feet of washes to prevent any
contamination from accidental petroleum, oil, and lubricants (POL) spills that could occur.
Additionally, the primary pedestrian fence within washes would be designed and constructed to
ensure that the primary pedestrian fence does not impede flow nor contribute significantly to
sedimentation or erosion within the washes. Therefore, no significant impacts to surface waters
would be expected.
Indirect impacts associated with the construction process would be insignificant, and minimized
through the implementation of mitigation measures discussed in Section 6.0. Additional indirect
impacts to water quality outside of the project corridor could also occur as IAs attempt to
circumvent the proposed infrastructure. However, it is unknown at this time where, when, or if IAs
will try to circumvent the project corridor, as this is completely out of USBP control and totally at
the IAs’ discretion. Although it is unknown where IAs might try to circumvent the proposed
infrastructure, the primary pedestrian fence would act as a force multiplier and allow USBP to

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deploy agents to unprotected areas. Thus, any potential indirect impacts to water resources
outside the project corridor would be further minimized.
4.10

SOCIOECONOMICS

4.10.1 Alternative 1: No Action Alternative
No impacts to the region’s socioeconomic resources would occur under the No Action Alternative,
as no construction activities would take place. However, the current level of illegal pedestrian
traffic would continue at its current rate and possibly increase. As a result, illegal traffic and the
crimes and social costs associated with it would also continue or increase; thus, long-term,
adverse socioeconomic impacts across the region would be incurred.
4.10.2 Alternative 2: Proposed Action Alternative
Direct beneficial impacts from the Proposed Action Alternative include minor and temporary
increases in sales volumes, housing demands for construction crews, material purchases, and
sales taxes. Additionally, implementation of the Proposed Action Alternative would reduce the
amount of illegal pedestrian traffic in the region, which, in turn, would reduce the associated
societal and economic costs to the region. These societal and economic costs include but are not
limited to the costs of removal of trash, overall degradation of property, reduction in property
value, and degradation of natural and cultural resources (i.e., OPCNM).

Consequently, this

reduction in illegal traffic would have an indirect beneficial long-term impact to the local economy.
Impacts regarding E.O. 13045 and E.O. 12898 from the implementation of the Proposed Action
Alternative would be similar to those previously discussed in the 2003 Final EA and are
incorporated herein by reference (NPS 2003). Given the remote location of the primary pedestrian
fence, there is no potential for disproportionately high and adverse impacts to minority populations
and low income families. The primary pedestrian fence would reduce illegal traffic north of the
project corridor, making it safer for everyone regardless of race, nationality, age, or income level.
Therefore, no significant impacts relative to environmental justice or protection of children issues
are expected as a result of the Proposed Action Alternative.
Indirect impacts could occur to areas outside of the project corridor if illegal pedestrian traffic shifts
to other areas of the U.S.-Mexico border (i.e., TON). However, it is impossible to determine what
those impacts would be, if any, as the direction or lack there of is solely at the discretion of the

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IAs. As mentioned previously, the primary pedestrian fence would allow USBP to deploy agents
to those areas lacking infrastructure to minimize impacts from any potential shift in IA traffic.
4.11

NOISE

4.11.1 Alternative 1: No Action Alternative
No noise impacts would occur as a result of the No Action Alternative because construction
activities would not occur. However, indirect adverse impacts from illegal pedestrian traffic and
consequent USBP enforcement activities would continue and possibly increase.
4.11.2 Alternative 2: Proposed Action Alternative
Noise levels created by the transport of construction vehicles, construction equipment, and
construction activities would vary depending on several factors, such as climatic conditions,
season, and the condition of the equipment. All construction and transport activities would
occur during daylight hours. OPCNM and its associated Wilderness Area are considered
sensitive noise receptors within the region. However, noise levels would decrease to an inaudible
level as the distance between the construction activities and the noise receptors (OPCNM and
Wilderness Area) increases. As mentioned in Section 3.11, noise from construction equipment
would be reduced to 55 dBA (i.e., acceptable noise level) within 2,600 feet. Additionally, the
project corridor is located adjacent to the Lukeville POE and Sonoyta, Mexico, which are
constant sources of noise within the region. Therefore, because the increased noise levels would
be temporary and minor, no direct significant impacts to ambient noise levels would occur upon
completion of construction.
Indirect impacts as a result of IAs trying to circumvent the proposed infrastructure could occur to
areas outside the project corridor. However, it is impossible for USBP to determine how much of
the illegal traffic would shift either to the east, west, or be eliminated completely.
4.12

AESTHETICS

4.12.1 Alternative 1: No Action Alternative
No impacts to aesthetics would occur upon implementation of the No Action Alternative as no
construction activities would occur. However, indirect adverse impacts to aesthetics as a result
of IAs trampling vegetation and leaving trash and debris would continue and possibly increase.

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4.12.2 Alternative 2: Proposed Action Alternative
The construction of 0.65 miles of primary pedestrian fence over the Sonoyta Hill would create
additional impacts as compared to the No Action Alternative. However, due to the existing
infrastructure surrounding Sonoyta Hill combined with mitigation measures (see Section 6.8),
these impacts would not be considered significant. The construction of 5.2 miles of primary
pedestrian fence would not differ substantially from the existing border infrastructure (e.g., chain
link fence, PVBs). In addition, the Lukeville POE, illegal trails, trash, and developments within
Sonoyta, Mexico also detract from the visual qualities of the project corridor, as shown previously
in Photographs 3-1 through 3-3. A short term minimal impact to aesthetics would occur during
construction; however, there would be no long term significant adverse impacts on the visual
quality of the region.
Indirect adverse impacts related to the possibility of IAs circumventing the proposed primary
pedestrian fence would be similar to those mentioned previously. Beneficial indirect impacts
would be expected as the primary pedestrian fence would eliminate IA traffic and associated trash
and illegal trails in the project corridor.
4.13

Hazardous and Solid Waste

4.13.1 Alternative 1: No Action Alternative
No impacts regarding hazardous or solid waste are expected, as no construction activities would
occur.
4.13.2 Alternative 2: Proposed Action Alternative
The potential exists for POL spills to occur while refueling construction equipment used during
the implementation of the Proposed Action Alternative. However, clean-up materials (e.g., oil
mops) would be maintained at the project site to allow immediate action in case an accidental
spill occurs. Drip pans would be provided for stationary equipment to capture any POL that is
accidentally spilled during maintenance activities or leaks from equipment. In addition, a Spill
Prevention, Control, and Countermeasures Plan (SPCCP) would be in place prior to the start of
construction, and all personnel would be briefed on the implementation and responsibilities of
this plan. OPCNM would be provided a copy of the SPCCP prior to construction activities.

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Final

Sanitary facilities would be provided during construction activities and waste products would be
collected and disposed of by licensed contractors. No gray water would be discharged to the
ground. Disposal contractors would disposed of all waste in strict compliance with Federal, state,
and local regulations, in accordance with the contractor’s permits.
The proposed infrastructure would also have indirect beneficial impacts through the reduction of
solid waste. As illegal foot traffic is reduced or eliminated within the project corridor, so would the
solid waste that is associated with it.

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SECTION 5.0
CUMULATIVE IMPACTS

5.0

CUMULATIVE IMPACTS

This section of the EA addresses the potential cumulative impacts associated with the
implementation of the alternatives and other projects/programs that are planned for the region.
The CEQ defines cumulative impacts as “the impact on the environment which results from the
incremental impact of the action when added to other past, present, and reasonably foreseeable
actions regardless of what agency (Federal or non-Federal) or person undertakes such other
actions” (40 CFR 1508.7).

This section continues, “Cumulative impacts can result from

individually minor but collectively significant actions taking place over a period of time.”
USBP has been conducting law enforcement actions along the border since its inception in
1924 and has continuously transformed its methods as new missions, IA modes of operations,
agent needs and national enforcement strategies have evolved. Development and maintenance
of training ranges, station and sector facilities, detention facilities, and roads and fences have
impacted thousands of acres with synergistic and cumulative impacts to soil, wildlife habitats,
water quality, and noise. Beneficial effects, too, have resulted from the construction and use of
these roads and fences including, but not limited to, increased employment and income for
border regions and its surrounding communities; protection and enhancement of sensitive
resources north of the border; reduction in crime within urban areas near the border; increased
land value in areas where border security has increased; and increased knowledge of the
biological communities and pre-history of the region through numerous biological and cultural
resources surveys and studies.
With continued funding and implementation of CBP’s environmental conservation measures,
including environmental education and training of its agents; use of biological and archeological
monitors; wildlife water systems; and restoration activities, adverse impacts due to future and
on-going projects would be avoided or minimized. However, recent, on-going and reasonably
foreseeable proposed projects will result in cumulative impacts. In particular, within the next 2
years, 225 miles are scheduled to be completed. The first phase of construction would occur in
areas that have already been developed (e.g., currently contains PVB or temporary vehicle
barriers [TVB]) and thus, little or no additional environmental impacts would be expected. The
second phase of construction would generally occur in more remote areas, and would inevitably
result in cumulative impacts.

EA – Primary Fence, Ajo

It should be noted that the final locations for the primary

5-1

Final

pedestrian fence have not been determined yet so, these should be considered only as planning
estimates.
A list of the past, on-going, and other proposed projects within the region surrounding the Ajo
Station’s AO are summarized in Table 5-1:
Table 5-1. Recently Completed or Reasonably Foreseeable USBP projects in Ajo
Station’s AO
Approximate
Distance from
Project
Corridor (miles)

Project
Installation of 26 emergency beacons within the CPNWR and
BMGR
Implementation of Operation Skywatch (a seasonal search and
rescue mission using helicopters and fixed-wing aircraft)
Proposed construction of 36 miles of pedestrian barrier, 35 miles
of patrol and drag road, eight water wells, two new temporary
staging areas, five existing staging areas, and approximately 7.5
miles of improvements to north-south access roads
Proposed acquisition of 30 acres adjacent to the USBP Ajo
Station for horse corral, station expansion, and parking
Proposed installation of five camp details, access and
maintenance of approximately 300 miles of roads on CPNWR
and BMGR, installation of eight temporary vehicle barriers,
construction of 104 miles of all-weather road, construction of
114 miles of drag roads, and construction of approximately 36
miles of permanent vehicle barriers on the CPNWR
Proposed installation of two additional rescue beacons on
CPNWR
Proposed installation of 12 RVS systems along the U.S.-Mexico
border south of Ajo, Arizona
Proposed improvement of 80 miles of all weather patrol road and
construction of 50 miles of PVBs on TON as well as a
construction access road for the installation and maintenance of
the PVBs
Proposed installation of a water well and upgrade of Desert Grip
camp detail including road improvements in the Wellton Station’s
AO
New infrastructure at the Lukeville – Sonoyta crossing including
office space, light industrial space, health unit space, and
warehouse/storage space (Garcia 2007)
Proposed widening of the El Camino Del Diablo to approximately
18-feet wide.
Proposed installation of 14 tower sites in the Ajo Station AO.
Total

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5-2

Approximate
Acres
Permanently
Impacted

24

0

0

0

70

198

30

30

40

589

18

0

30

1

15

72

25

14

0

1

15

62

15

7
974 acres

Final

The USBP might be required to implement other activities and operations that are currently not
foreseen or mentioned in this document.

These actions could be in response to National

emergencies or security events like the terrorist attacks on September 11, 2001 or to changes in
the mode of operations of the potential IAs.
In addition, projects are currently being planned by other Federal entities which could affect areas
in use by USBP. CBP should maintain close coordination with these agencies to ensure that CBP
activities do not conflict with other agency(s) policies or management plans. CBP will consult with
applicable state and Federal agencies prior to performing any construction activities and will
coordinate operations so that it does not impact the mission of other agencies. The following is a
list of projects other Federal agencies and tribes are conducting or have completed within the
U.S.-Mexico border region.
OPCNM:
1.

Planned installation of fiber optic cable along State Route 85 from the northern
boundary of the OPCNM to the Visitors Center (Kralovec 2007b).

2.

Proposed installation of approximately 2 miles of new water line from the Visitors
Center to the Camp Grounds (Kralovec 2007b).

A summary of the anticipated cumulative impacts relative to the Proposed Action Alternative
(i.e., construction of 5.2 miles of primary pedestrian fence within the Ajo Station) is presented
below. These discussions are presented for each of the resources described previously.
Land Use. A significant impact would occur if any action is inconsistent with adopted land use
plans or an action would substantially alter those resources required for, supporting or
benefiting the current use. The Proposed Action Alternative would only permanently affect 45
acres, of which 38 are located in the Roosevelt Reservation that was set aside specifically for
border control actions. The use of 7 acres of NPS lands on the OPCNM would not be
considered cumulatively significant as the OPCNM encompasses over 330,000 acres and the
impact would account for less than 0.002 percent of the OPCNM total acreage. In addition, a
Special Use Permit would be obtained by USBP for the use of this land for construction of the
road and fence which acts as a tool to protect the remainder of the park. Therefore, this action
within the Roosevelt Reservation is consistent with the authorized land use and, when

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considered with other potential alterations of land use, would not be expected to result in a
significant cumulative adverse effect.
Soils. A significant impact would occur if the action exacerbates or promotes long-term erosion,
if the soils are inappropriate for the proposed construction, and would create a risk to life or
property; or if there would be a substantial reduction in agricultural production or loss of prime
farmland soils. The proposed action and other USBP actions have not reduced prime farmland
soils or agricultural production.

Pre- and post-construction SWPPP measures would be

implemented to control soil erosion.

No inappropriate soil types are located in the project

corridor that would present a safety risk.

The impact to 45 acres, including 17 acres of

previously disturbed soils, when combined with past and proposed projects in the region, would
not be considered a significant cumulative adverse impact.
Biological Resources. The significance threshold for biological resources would include a
substantial reduction in ecological process, communities, or populations that would threaten the
long-term viability of a species or result in the substantial loss of a sensitive community that
could not be off-set or otherwise compensated. Removal of 28 acres of locally common habitat
would result in insignificant cumulative impacts to vegetation communities and wildlife
populations since habitat in the project corridor is regionally common. The long-term viability of
species and communities in the project region would not be threatened. The loss of 28 acres of
wildlife habitat, when combined with other ground disturbing or development projects in the
project region, would not result in significant cumulative negative impacts on the region’s
biological resources.
Cultural Resources.

The proposed action would have no effect on cultural resources.

Therefore, this action, when combined with other existing and proposed projects in the region,
would not result in significant cumulative impacts to historical properties.
Air Quality. Impacts to air quality would be considered significant if the action resulted in a
violation of air quality standards, obstructs implementation of an air quality plan, or exposes
sensitive receptors to substantial pollutant concentrations. The emissions generated during and
after the construction of the proposed primary pedestrian fence would be short-term and minor.
Although maintenance of the primary pedestrian fence would result in cumulative impacts to the
region’s airshed, these impacts would not be considered significant even when combined with

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the other proposed developments in the border region. Deterrence of and improved response
time to IAs created by the construction of the primary pedestrian fence would reduce off-road
enforcement actions that are currently required by USBP agents.
Water Resources.

The significance threshold for water resources include any action that

substantially depletes groundwater or surface water supplies or interferes with groundwater
recharge, substantially alters drainage patterns, or results in the loss of waters of the U.S. that
cannot be compensated. No significant impact to water resources would occur as a result of the
construction and maintenance of the proposed primary pedestrian fence. The required SWPPP
and BMPs would reduce erosion and sedimentation during construction to negligible levels and
would eliminate post-construction erosion and sedimentation from the site. The same measures
would be implemented for other construction projects; therefore, cumulative impacts would not
be significant.
Socioeconomics. Significance threshold for socioeconomic conditions include displacement or
relocation of residences or commercial buildings; increases in long-term demands to public
services in excess of existing and projected capacities; and disproportionate impacts to minority
and low income families. Construction of the proposed infrastructure would result in temporary
cumulative beneficial impacts to the region’s economy.

No impacts to residential areas,

population, or minority or low-income families would occur. These effects, when combined with
the other currently proposed or on-going projects within the region, would not be considered as
significant cumulative impacts.
Noise. Actions would be considered to cause significant impacts if they permanently increase
ambient noise levels over 65 dBA. Most of the noise generated by the proposed action would
occur during construction and, thus, would not contribute to cumulative impacts to ambient
noise levels.

Routine maintenance of the primary pedestrian fence would result in slight

temporary increases in noise levels that would continue to sporadically occur over the long-term
and would be similar to ongoing PVB maintenance within the project corridor. Potential sources
of noise from other projects are not enough (temporal or spatial) to increase ambient noise
levels above the 65 dBA range at the proposed sites.

Thus, the noise generated by the

construction and maintenance of the proposed infrastructure, when considered with the other
existing and proposed projects in the region, would not be considered a significant cumulative
adverse effect.

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Aesthetics. Actions that cause the permanent loss of the characteristics that make an area
visually unique or sensitive would be considered to cause a significant impact.

No major

impacts to visual resources would occur from implementing the proposed action, due in part to
the heavily degraded nature of the project corridor, development on the south side of the border,
and the existing border tactical infrastructure. Construction and maintenance of the proposed
primary pedestrian fence, when considered with existing and proposed developments in the
surrounding area, would not result in a significant cumulative negative impact on the visual
quality of the region. Areas north of the border would experience beneficial, indirect cumulative
effects by the reduction of trash and debris produced by IAs.
Hazardous and Solid Wastes. Significant impacts would occur if an action creates a public
hazard, the site is considered a hazardous waste site that poses health risks, or if the action
would impair the implementation if an adopted emergency response or evacuation plan. Only
minor increases in the use of hazardous substances (e.g., POL) would occur as a result of the
construction and maintenance of the primary pedestrian fence. No health of safety risks would
be created by the proposed action. The effects of this proposed action, when combined with
other on-going and proposed projects in the region, would not be considered a significant
cumulative effect.

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SECTION 6.0
MITIGATION MEASURES

6.0

MITIGATION MEASURES

This chapter describes those measures that would be implemented to reduce or eliminate
potential adverse impacts to the human and natural environment. Many of these measures have
been incorporated as standard operating procedures by USBP on past projects. It is USBP policy
to mitigate adverse impacts through the sequence of avoidance, minimization, and finally,
compensation. Mitigation measures are presented below for each resource category that would
be potentially affected. It should be noted that if any of the alternatives for this project are
implemented, the following mitigation measures could be employed.
6.1

GENERAL CONSTRUCTION ACTIVITIES

BMPs would be implemented as standard operating procedures during all construction activities,
and would include proper handling, storage, and/or disposal of hazardous and/or regulated
materials. To minimize potential impacts from hazardous and regulated materials, all fuels, waste
oils and solvents would be collected and stored in tanks or drums within a secondary containment
system that consists of an impervious floor and bermed sidewalls capable of containing the
volume of the largest container stored therein. The refueling of machinery would be completed
following accepted industry guidelines, and all vehicles could have drip pans during storage to
contain minor spills and drips. Although it will be unlikely for a major spill to occur, any spill of
reportable quantities would be contained immediately within an earthen dike, and the application
of an absorbent (e.g., granular, pillow, sock, etc.) would be used to absorb and contain the spill.
Furthermore, any petroleum liquids (e.g., fuel) or material listed in 40 CFR 302 Table 302.4 of a
reportable quantity must be cleaned up and reported to the appropriate Federal and state
agencies. Reportable quantities of those substances listed on 40 CFR 302 Table 302.4 would be
included as part of the SPCCP. A SPCCP would be in place prior to the start of construction and
all personnel would be briefed on the implementation and responsibilities of this plan.
All construction would follow DHS management directive 5100 for waste management. All waste
oil and solvents would be recycled. All non-recyclable hazardous and regulated wastes would
be collected, characterized, labeled, stored, transported and disposed of in accordance with all
Federal, state, and local regulations, including proper waste manifesting procedures.

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Solid waste receptacles would be maintained at staging and bivouac areas. Non-hazardous solid
waste (trash and waste construction materials) would be collected and deposited in the on-site
receptacles. Solid waste would be collected and disposed of by a local waste disposal contractor.
Waste materials and other discarded materials would be removed from the site as quickly as
possible in an effort to keep the project area and surroundings free of litter.
Waste water (water used for project purposes that is contaminated with construction materials,
was used for cleaning equipment and thus carries oils or other toxic materials or other
contaminants in accordance with state regulations) is to be stored in closed containers on site
until removed for disposal. Concrete wash water would not be dumped on the ground, but is to
be collected and moved offsite for disposal.
6.2

SOILS

Erosion control techniques, such as the use of straw bales (weed free straw), aggregate
materials, wetting compounds (i.e., water) and revegetation with native plant species, where
possible, would be incorporated with the design of the Proposed Action Alternative. In addition,
other erosion control measures, as required and promulgated through the SWPPP, would be
implemented before and after construction activities.
6.3

BIOLOGICAL RESOURCES

All contractors, work crews (including National Guard and military personnel), and CBP
personnel in the field performing construction and maintenance activities would receive training
on the habitat and habits of the species that are found in the area, including information on how
to avoid impacts to the species from their activities. This training would be provided to all
contractor and work crew project managers and senior military leaders who are working onsite.
It would be the responsibility of these project managers and senior military leaders to ensure
that their personnel are familiar with the BMPs and other limitations and constraints.
CBP would truck water into the project site for purposes of construction to ensure that no
impacts to flora or fauna near and within Quitobaquito Springs would occur.

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Final

The MBTA requires that Federal agencies coordinate with USFWS if a construction activity would
result in the “take” of a migratory bird.

Since construction or clearing activities cannot be

scheduled to avoid the nesting season (typically March 15 through September 15),
preconstruction surveys for migratory bird species would occur immediately prior to the start of
any construction activity to identify active nests. If construction activities would result in the “take”
of a migratory bird, then coordination with USFWS and AGFD would occur, and applicable
permits would be obtained prior to construction or clearing activities.
Although no Sonoran desert tortoises or Mexican rosy boas were observed during biological
surveys the potential exists for these species to occur in and near Sonoyta Hill. In the event a
tortoise or boa is observed within the construction corridor during construction activities, a
qualified biologist would capture and relocate the individual to an area outside of the corridor but
still on Sonoyta Hill.
CBP would truck water into the project site for purposes of construction to ensure that no
impacts to flora or fauna near and within Quitobaquito Springs would occur.
A salvage plan would be developed by the CBP, in close coordination with NPS, prior to
construction activities. CBP will salvage as many columnar cacti as possible. CBP will develop
and fund a restoration plan, in coordination with the NPS to restore illegal trails and roads on
OPCNM. This will enhance bat foraging opportunities.
Materials used for on-site erosion control would be free of non-native plant seeds and other
plant parts to limit potential for infestation. Additionally, all areas within the construction footprint
would be monitored for a period of three years for the spread and eradication of non-native and
invasive species. Construction equipment would be cleaned using BMPs prior to entering and
departing the OPCNM to minimize the spread and establishment of non-native and invasive
species.
6.4

CULTURAL RESOURCES

Construction near the Gachado Line Camp would be monitored by a professional archeological
monitor to ensure no impacts would occur. Buffers would be established around the three historic
objects that lie within the proposed construction corridor in order to avoid any adverse effects to

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Final

these significant cultural resources. If any cultural material is discovered during the construction
efforts, then all activities would halt until a qualified archeologist can be brought in to assess the
cultural remains.
6.5

WATER RESOURCES

Standard construction procedures would be implemented to minimize the potential for erosion and
sedimentation during construction.

All work would cease during heavy rains and would not

resume until conditions are suitable for the movement of equipment and material. In accordance
with regulations of the EPA Phase II of the NPDES stormwater program, a SWPPP would be
required for stormwater runoff from construction activities greater than 1 acre and less than 5
acres. Therefore, a SWPPP would be prepared and the NOI submitted prior to the start of any
construction. Equipment required for the construction activities would not be staged or stored
within 100 feet of any wash to prevent any contamination from accidental POL spills that could
occur. Primary pedestrian fence constructed in washes/arroyos would be designed to ensure
proper conveyance of floodwaters and to eliminate the potential to cause backwater flooding on
either side of the U.S.-Mexico border. Immediately after rain events, CBP would be responsible for
ensuring that debris is removed from the primary pedestrian fence within washes/arroyos to
ensure that no backwater flooding occurs. Additionally, all concrete trucks would be washed and
cleaned outside of the project corridor and OPCNM lands.
6.6

AIR QUALITY

Standard construction practices such as routine watering of the construction site would be used to
control fugitive dust during the construction phases of the proposed project. Additionally, all
construction equipment and vehicles would be required to be kept in good operating condition to
minimize exhaust emissions.
6.7

NOISE

During the construction phase, short-term noise impacts are anticipated. All Occupational Safety
and Health Administration requirements would be followed. On-site activities would be restricted
to daylight hours with the exception of concrete pours and emergency situations. Construction
equipment would possess properly working mufflers and would be kept properly tuned to reduce

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Final

backfires.

Implementation of these measures would reduce the expected short-term noise

impacts to an insignificant level in and around the construction site.
6.8

AESTHETICS

In order to minimize potential aesthetic impacts over Sonoyta Hill, CBP would use subdued and
non-reflective materials to build the primary pedestrian fence. These materials are expected to
blend with the landscape as it naturally rusts.

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Final

SECTION 7.0
PUBLIC INVOLVEMENT

7.0

PUBLIC INVOLVEMENT

7.1

AGENCY COORDINATION

This chapter discusses consultation and coordination that has occurred during preparation of this
document. Agency correspondence and consultation letters are included in Appendix C. Formal
and informal coordination has been conducted with the following agencies:
•
•
•
•
•
•
•
•
•
•
•
7.2

U.S. Fish and Wildlife Service (USFWS)
U.S. Environmental Protection Agency (EPA)
U.S. Section, International Boundary and Water Commission (USIBWC)
Natural Resource Conservation Service (NRCS)
Arizona State Historic Preservation Office (SHPO)
Arizona Game and Fish Department (AGFD)
Pima County Department of Environmental Quality
National Park Service (NPS)
Organ Pipe Cactus National Monument (OPCNM)
U.S. Army Corps of Engineers, Los Angeles District (USACE)
Federally Recognized Tribes

PUBLIC REVIEW

The draft EA was made available for public review for a period of 30 days, beginning on
September 17, 2007, which is the day the Notice of Availability (NOA) was published in local
newspapers. A copy of the NOA that was published, announcing the availability of the draft EA, is
included on the following page. Comments received concerning the draft EA were addressed
and, where appropriate, changes were incorporated into the final EA.
During the public review period, comments were received from USIBWC, TON, OPCNM, and
AGFD.

Copies of the comment letters are included in Appendix C as well as the

comment/response matrix developed by CBP.

In summary, USIBWC expressed their

jurisdictional concerns pertaining to overland drainage flow into Mexico, maintenance of border
monuments, and the structural integrity of proposed primary pedestrian fence. AGFD expressed
its natural resource management concerns pertaining to habitat fragmentation and degradation,
as well as the need to coordinate its responsibilities with CBP’s mission. The OPCNM expressed
concerns with traversing Sonoyta Hill and potential effects to groundwater supplies. The TON was

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Final

mainly concerned with viewshed and cultural landscape issues, and indirect effects of shifts in
illegal traffic to the TON (see Appendix C).
Revisions to the Draft EA have been incorporated, as appropriate, to this Final EA, based on the
comments received. In addition, CBP has coordinated with OPCNM to ensure that its primary
concerns have been sufficiently addressed in this document.

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Final

SECTION 8.0
REFERENCES

8.0

REFERENCES

Arizona Department of Commerce. 2004. Community Profile: Sells/Tohono O’odham
Reservation
website.
Internet
Address:
http://www.commerce.state.az.us/doclib/commune/sells.pdf.
Arizona Department of Commerce. 2005. Pima County Profile – Pima County Unemployment
Rate.
Internet
URL:
http://www.azcommerce.com/doclib/COMMUNE/Pima%20County.pdf. Last accessed:
May 8, 2007.
Arizona Department of Water Resources (ADWR). 2004. Internet Resource: www.water.az.gov.
ADWR. 2005. Western Mexican Drainage Basin Information Page. Internet Address:
http://www.water.az.gov/adwr/Content/WaterInfo/OutsideAMAs/LowerColorado/Basins/w
esternmexicandrainage.html. Last Accessed: May 2, 2005.
Arizona Game and Fish Department (AGFD). 2003. Leptonycteris curasoae yerbabuenae.
Unpublished abstract compiled and edited by the Heritage Data Management System,
Arizona Game and Fish Department, Phoenix, AZ. 8pp.
AGFD. 2004. Echinocactus erectocentrus var. acuñensis. Unpublished abstract compiled and
edited by the Heritage Data Management System, Arizona Game and Fish Department,
Phoenix, AZ. 7pp.
Arizona Wilderness Coalition. 2004.
www.azwild.org/whywild/index.

What

is

Wilderness?

Internet

Address:

Babcock, H.M., Brown, S.C., and Hem, J.D., 1947, Geology and ground-water resources of the
Wellton-Mohawk area, Yuma County, Arizona: U.S. Geological Survey Open-File.
Barry M. Goldwater Range (BMGR). No publication date. Visitors Information Brochure.
Bugliarello, G., Alexandre, A., Barnes, J., and Wakstein, C. 1976. The Impact of Noise
Pollution: A Socio-Technological Introduction. New York: Pergamon Press.
Bureau of Economic Analysis (BEA). 2005. Total and Full Time Employment by
Industry,
Pima
County,
Arizona.
URL:http://www.bea.gov/regional/reis/action.cfm. Last accessed: May 8, 2007.

Internet

Defenders of Wildlife. 2004. Habitat, National Wildlife Refuges, Arizona, Profiled Refuge:
Cabeza Prieta. Internet Address: http://www.defenders.org/habitat/refuges/map/az.html.
Desert USA. 2004a. Organ Pipe Cactus National Monument Description webpage. Internet
Address: www.desertusa.com/organ/du_orgdesc.html.
Desert USA 2004b. Organ Pipe Cactus National Monument Main web page. Internet Address:
www.desertusa.com/organ/du_org_main.html.

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8-1

Final

Generac Power Systems, Inc. 2004. Technical Perspective: Sound Measurement and
Attenuation. Bulletin 0170310SBY. Waukesha, Wisconsin.
Gilpin, M.E. and Hanski, I. 1991. Metapopulation Dynamics: Empirical and Theroretical
Investigations. London: Linnaean Society of London and Academic Press.
Good Neighbor Environmental Board, 2006. The Ninth Report of the Good Neighbor
Environmental Board to the President and Congress of the United States. Pages 34-35.
Internet Website: http://www.epa.gov/ocem/gneb/gneb9threport/English-GNEB-9thReport.pdf. Last accessed: August 11, 2006.
Gulf South Research Corporation. 2007. Air Quality Model Calculations for the Monument 250
Road Improvement Project. Gulf South Research Corporation, Baton Rouge, Louisiana.
5 p.
Immigration and Naturalization Service (INS). 2001. Programmatic Environmental Impact
Statement for the Continuation of Immigration and Naturalization Service /Joint Task Force
– Six Operations, Port Arthur, Texas to San Diego, California. U.S. Army Corps of
Engineers, Fort Worth District.
INS 2002. INS, U.S. Border Patrol, U.S. Department of Interior, U.S. Forest Service, U.S.
Environmental Protection Agency. 2002. Report to the House of Representatives
Committee on Appropriations on Impacts Caused by Undocumented Aliens Crossing
Federal Lands in Southeast Arizona.
Inter Tribal Council of Arizona. 2003. Tohono O’odham Nation Introductory Information web
page. Internet Address: www.ictaonline.com/tribes_tohono.html.
Kralovec, Mary. 2007a. Personal Communication via telephone between Ms. Mary Kralovec of
the Organ Pipe Cactus National Monument and Mr. Josh McEnany of Gulf South
Research Corporation (GSRC). August 29, 2007.
Kralovec, Mary. 2007b. Personal Communication via telephone between Ms. Mary Kralovec of
the Organ Pipe Cactus National Monument and Mr. Josh McEnany of Gulf South
Research Corporation (GSRC). June 13, 2007.
Leake, Stanley. 2005. Personal Communication via electronic mail from Mr. Stanley Leake of
the U.S. Geological Survey to Mr. Josh McEnany of GSRC. June 20, 2005.
Mid-Atlantic Regional Air Management Association (MARAMA) 2006. Fugitive DustConstruction
Calculation
Sheet
can
be
found
online
at:
http://www.marama.org/visibility/Calculation_Sheets/
NPS.

2003. Environmental Assessment for Proposed Vehicle Barrier, Organ Pipe Cactus
National Monument-Coronado National Memorial. December 2003.

NPS. 2004. Organ Pipe Cactus National Monument webpage.
www.nps.gov/orpi/.

Internet Address:

NPS. 2005. Organ Pipe Cactus National Monument Nature & Science Environmental Factors
web page. Internet Address: www.nps.gov/orpi/pphtml/environmentalfactors.html.

EA – Primary Fence, Ajo

8-2

Final

Pima County. 2001. Sonoran Desert Conservation Plan. Pima County, Arizona Board of
Supervisors.
Internet
Resource:
http://www.co.pima.az.us/cmo/sdcp/sdcp2/pvs/pdfs/vulsp.pdf.
Pima County Department of Environmental Quality, 2007. Air Info Now. Internet Website:
http://www.airinfonow.com/html/data.html.
Tibbett, Betty. 2005. Personal communication between Betty Tibbett of Why Utility Company,
Why, Arizona and Joanna Cezniak, GSRC regarding Why Utility Company’s
infrastructure availability. Telephone conversation conducted on October 5, 2004.
Tibbits, Tim. 2007. Personal Communication via telephone between Mr. Tim Tibbits of the
Organ Pipe Cactus National Monument and Mr. Josh McEnany of Gulf South Research
Corporation (GSRC). November 27, 2007.
Tuomey, Joe. 2007. Personal Communication via telephone between Mr. Joe Tuomey of the
Organ Pipe Cactus National Monument and Mr. Josh McEnany of Gulf South Research
Corporation (GSRC). August 29, 2007.
U.S Census Bureau. 2005. Pima County, Arizona – Fact Sheet – American Fact
Finder. Internet URL:
http://factfinder.census.gov/servlet/ACSSAFFFacts?_event=Search&geo_id=&_g
eoContext=&_street=&_county=pima+county&_cityTown=pima+county&_state=0
4000US04&_zip=&_lang=en&_sse=on&pctxt=fph&pgsl=010. Last accessed:
May 8, 2007.
U.S. Customs and Border Patrol (CBP). 2003. Performance and Annual Report: Fiscal Year
2003.
U.S. Departments of Air Force, Navy, and Interior. 2006. Final Environmental Impact
Statement for the Barry M. Goldwater Range, Proposed Integrated Natural Resource
Management Plan. February 2006.
U.S. Environmental Protection Agency (EPA). 1974. Information on Levels of Environmental
Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety.
Report 550/9-47-004.
EPA. 2006. Welcome to the Green Book Nonattainment Areas for Criteria Pollutants. Internet
website: www.epa.gov/oar/oaqps/greenbk
EPA.

2007a.Enforcement & Compliance History Online (ECHO). Internet
http://www.epa.gov/cgi-bin/ideaotis.cgi. Last Accessed: May 22, 2007.

Address:

EPA.

2007b.Envirofacts
Data
Warehouse
website.
Internet
http://www.epa.gov/enviro/index_java.html. Last Accessed: May 22, 2007.

Address:

U.S. Fish and Wildlife Service (USFWS). Endangered and Threatened Wildlife and Plants;
Determination of Endangered Status and Critical Habitat for the Desert Pupfish
(Cyprinodon macularius); Final Rule. Federal Register 51(61):1084210851, March 31,
1986.

EA – Primary Fence, Ajo

8-3

Final

USFWS. 1995. Lesser Long-nosed Bat Recovery Plan.
Albuquerque, New Mexico. 45pp.

U.S. Fish and Wildlife Service,

USFWS. 1998. Final Revised Sonoran Pronghorn Recovery Plan, Albuquerque, New Mexico.
70pp.
USFWS. 2001. Cultural Resources Overview and Assessment for the Cabeza Prieta National
Wildlife Refuge. Prepared by SWCA, Inc. (Cultural Resource Report No. 01-24). Tucson,
Arizona. Edited by Richard Ahlstrom. August 2001.
USFWS. 2002.
Cabeza Prieta National Wildlife Refuge.
http://www.fws.gov/southwest/refuges/arizona/cabeza.html.

Internet

Address:

USFWS. 2003. Supplement and Amendment to the 1998 Final Revised Sonoran Pronghorn
Recovery Plan (Antilocapra americana sonoriensis). U.S. Fish and Wildlife Service,
Albuquerque, New Mexico. I-iv + 60 pp., A1-3, B1-30, C1-8.
USFWS. 2005. Cabeza Prieta National Wildlife Refuge Draft Comprehensive Conservation Plan
Wilderness Stewardship Plan and Environmental Impact Statement. U.S. Fish and
Wildlife Service, Region 2, Albuquerque, New Mexico. January 2005.
USFWS. 2007. Arizona Threatened, Endangered, and Candidate Species: Pima and Yuma
counties. USFWS, Arizona Ecological Services Field Office. Internet Website:
http://arizonaes.fws.gov/.
Weist, W.G., 1965, Geohydrology of the Dateland-Hyder area, Maricopa and Yuma Counties,
Arizona: Arizona State Land Department Water Resources Report Number 23, 46p.

EA – Primary Fence, Ajo

8-4

Final

SECTION 9.0
LIST OF PREPARERS

EA – Primary Fence, Ajo

9-1

Final

LIST OF PREPARERS

Gulf South Research Corporation

Gulf South Research Corporation

Gulf South Research Corporation

Gulf South Research Corporation

Gulf South Research Corporation
Gulf South Research Corporation
Gulf South Research Corporation
Gulf South Research Corporation

Eric Webb, Ph.D.

Chris Ingram

Josh McEnany

Sharon Newman

Howard Nass
Shanna McCarty
Steve Kolian
Joanna Cezniak

9-1

Charles McGregor

Suna Adam Knaus

Architect-Engineer Resource
Center

AGENCY/ORGANIZATION

USACE, Fort Worth District,
AERC
Gulf South Research Corporation

Patience E.
Patterson, RPA

NAME

Forestry/Wildlife
Forestry
Environmental Science
Wildlife

GIS/graphics

Forestry/Wildlife

Biology/ Ecology

Ecology/Wetlands

Forestry/Wildlife

NEPA

Archaeology

DISCIPLINE/EXPERTISE

7 years, natural resources and
NEPA studies
11 years, GIS/graphics
experience
17 years, natural resources
3 years natural resources
10 years natural resources
9 years natural resources

EA review
EA preparation
EA preparation
EA preparation

GIS/graphics

Project Manager

Project Coordinator/EA
technical review

EA technical review

15 years experience in natural
resources and NEPA studies
30 years EA/EIS studies

Project Manager, cultural
resources review, and EA
coordination
ECSO Project Manager, EA
review and coordination
EA review

ROLE IN PREPARING EA

29 years, Professional
Archeologist/Cultural Resource
Manager
10 years Environmental
Management and Review
17 years, natural resources

EXPERIENCE

The following people were primarily responsible for preparing this Environmental Assessment.

9.0

THIS PAGE LEFT INTENTIONALLY BLANK

EA – Primary Fence, Ajo

9-2

Final

SECTION 10.0
ACRONYMS

10.0

ACRONYMS

AO
ACHP
ADWR
AGFD
ARPA
BEA
BMP
BMGR
CAA
CBP
CEQ
CFR
CPNWR
CWA
DNL
dB
dBA
DHS
EA
EPA
E.O.
ESA
FONSI
FR
GNEB
GSRC
IA
INS
JTF-6
MBTA
MARAMA
MOU
NAAQS
NEPA
NHPA
NPDES
NPS
NRCS
NRHP
NOA
NOI
OPCNM
PCDEQ
PCPI
POE
POL
PVB
ROI

Area of Operation
Advisory Council on Historic Preservation
Arizona Department of Water Resources
Arizona Game and Fish Department
Archeological Resources Protection Act
Bureau of Economic Analysis
Best Management Practice
Barry M. Goldwater Range
Clean Air Act
U.S. Customs and Border Protection
Council on Environmental Quality
Code of Federal Regulations
Cabeza Prieta National Wildlife Refuge
Clean Water Act
Day-Night average sound Level
Decibel
A-weighted Decibel
Department of Homeland Security
Environmental Assessment
U.S. Environmental Protection Agency
Executive Order
Endangered Species Act
Finding of No Significant Impact
Federal Register
Good Neighbor Environmental Board
Gulf South Research Corporation
Illegal Alien
Immigration and Naturalization Service
Joint Task Force Six
Migratory Bird Treaty Act
Mid-Atlantic Regional Air Management Association
Memorandum of Understanding
National Ambient Air Quality Standards
National Environmental Policy Act of 1969
National Historic Preservation Act
National Pollutant Discharge Elimination System
National Park Service
Natural Resource Conservation Service
National Register of Historic Places
Notice of Availability
Notice of Intent
Organ Pipe Cactus National Monument
Pima County Department of Environmental Quality
Per Capita Personal Income
Port of Entry
Petroleum, Oils, and Lubricants
Permanent Vehicle Barrier
Region of Influence

EA – Primary Fence, Ajo

10-1

Final

SHPO
SPCCP
SPEIS
SWPPP
TON
TPI
TVB
U.S.
U.S.C.
USACE
USBP
USFWS
WSC
WMDB

State Historic Preservation Officer
Spill Prevention, Control, and Countermeasures Plan
Supplemental Programmatic Environmental Impact Statement
Storm Water Pollution Prevention Plan
Tohono O’odham Nation
Total Personal Income
Temporary Vehicle Barrier
United States
United States Code
U.S. Army Corps of Engineers
U.S. Border Patrol
U.S. Fish and Wildlife Service
Wildlife of Special Concern
Western Mexican Drainage Basin

EA – Primary Fence, Ajo

10-2

Final

APPENDIX A
March 2006 Memorandum of Understanding

access secured administrative roads/trails. CBP-BP may drag existing
public and administrative roads that are unpaved for the purpose of
cutting sign, subject to compliance with conditions that are mutually
agreed upon by the local Federal land manager and the CBP-BP Sector
Chief. For purposes of this MOU, "existing public roads/trails" are
those existing roads/trails, paved or unpaved, on which the land
management agency allows members of the general public to operate
motor vehicles, and "existing administrative roads/trails" are those
existing roads/trails, paved or unpaved, on which the land management
agency allows persons specially authorized by the agency, but not
members of the general public, to operate motor vehicles;
3 CBP-BP may request, in writing, that the land management agency
grant additional access to Federal lands (for example, to areas not
previously designated by the land management agency for off-road use)
administered by the DOI or the USDA for such purposes as routine
patrols, non-emergency operational access, and establishment of
temporary camps or other operational activities. The request will
describe the specific lands and/or routes that the CBP-BP wishes to
access and the specific means of access desired. After receiving a
written request, the local Federal land manager will meet promptly with
the CBP-BP Sector Chief to begin discussing the request and
negotiating the terms and conditions of an agreement with the local
land management agency that authorizes access to the extent permitted
by the laws applicable to the particular Federal lands. In each
agreement between CBP-BP and the local land management agency,
the CBP-BP should be required to use the lowest impact mode of travel
and operational setup reasonable and practicable to accomplish its
mission. The CBP-BP should also be required to operate all motorized
vehicles and temporary operational activities in such a manner as will
minimize the adverse impacts on threatened or endangered species and
on the resources and values of the particular Federal lands. However, at
no time should officer safety be compromised when selecting the least
impactful conveyance or operational activity. Recognizing the
importance of this matter to the Nation's security, the CBP-BP Sector
Chief and the local Federal land manager will devote to this endeavor
the resources necessary to complete required compliance measures in
order to execute the local agreement within ninety (90) days after the
Federal land manager has received the written request for access.
Nothing in this paragraph is intended to limit the exercise of applicable
emergency authorities for access prior to the execution of the local
agreement. The Secretaries of the Interior, Agriculture, and Homeland
Security expect that, absent compelling justification, each local
agreement will be executed within that time frame and provide the
maximum amount of access requested by the CBP-BP and allowed by
law;

-5-

APPENDIX B
List of State and Federal Protected Species for Pima County

Haliaeetus
leucocephalus

Pelecanus
occidentalis
californicus

Rana chiricahuensis

Cyprinodon
macularius

Bald eagle

California Brown
pelican

Chiricahua leopard
frog

Desert pupfish

Wednesday, May 17, 2006

SCIENTIFIC NAME

COMMON NAME

Pima County

Small (2 inches) smoothly
rounded body shape with
narrow vertical bars on the
sides. Breeding males blue
on head and sides with
yellow on tail. Females and
juveniles tan to olive colored
back and silvery sides.

Endangered

Graham, La Paz,
Maricopa, Pima,
Pinal, Santa Cruz,
Yavapai

Apache, Cochise,
Coconino, Gila,
Graham,
Greenlee, Navajo,
Pima, Santa Cruz,
Yavapai

Apache, Cochise,
Coconino, Gila,
Graham,
Greenlee, La Paz,
Maricopa,
Mohave, Navajo,
Pima, Pinal,
Santa Cruz,
Yavapai, Yuma

Apache, Cochise,
Coconino, Gila,
Graham, La Paz,
Maricopa,
Mohave, Navajo,
Pima, Pinal,
Santa Cruz,
Yavapai, Yuma

COUNTY

Pima County

Cream colored tubercules
(spots) on a dark background
on the rear of the thigh,
dorsolateral folds that are
interrupted and deflected
medially, and a call given out
of water distinguish this
spotted frog from other
leopard frogs.

Large dark gray-brown water
bird with a pouch underneath
long bill and webbed feet.
Adults have a white head
and neck, brownish black
breast, and silver gray upper
parts.

Large, adults have white
head and tail. Height 28-38
inches; wingspan 66-96
inches. Dark with varying
degrees of mottled brown
plumage. Feet bare of
feathers.

DESCRIPTION

Threatened

Endangered

Threatened

STATUS

Streams, rivers,
backwaters, ponds, and
stock tanks that are mostly
free from introduced fish,
crayfish, and bullfrogs.

Coastal land and islands;
species found around
many Arizona lakes and
rivers.

Large trees or cliffs near
water (reservoirs, rivers,
and streams) with
abundant prey.

HABITAT

Shallow springs, small
streams, and marshes.
Tolerates saline and warm
water.

3300-8900 ft

Varies

Varies

ELEVATION

< 5,000 ft

Page 1 of 5

Critical habitat includes Quitobaquito
Springs, Pima County, portions of San
Felipe Creek, Carrizo Wash, and Fish
Creek Wash, Imperial County, California.
Two subspeices are recognized: Desert
Pupfish (C.m.macularis) and Quitobaquito
Pupfish (C.m.eremus).

Require permanent or nearly permanent
water sources. Populations north of the
Gila River may be a closely-related, but
distinct, undescribed species. A special
rule allows take of frogs due to operation
and maintenance of livestock tanks on
State and private lands.

Subspecies is found on Pacific Coast and
is endangered due to pesticides. It is an
uncommon transient in Arizona on many
Arizona lakes and rivers. Individuals
wander up from Mexico in summer and
fall. No breeding records in Arizona.

Some birds are nesting residents while a
larger number winters along rivers and
reservoirs. An estimated 200 to 300 birds
winter in Arizona. Once endangered (32
FR 4001, 03-11-1967; 43 FR 6233, 02-1478) because of reproductive failures from
pesticide poisoning and loss of habitat,
this species was down listed to
threatened on August 11, 1995. Illegal
shooting, disturbance, and loss of habitat
continues to be a problem. Species has
been proposed for delisting (64 FR
36454) but still receives full protection
under the ESA.

COMMENTS

Gila intermedia

Poeciliopsis
occidentalis
occidentalis

Lilaeopsis
schaffneriana ssp.
recurva

Panthera onca

Amsonia
kearneyana

Gila chub

Gila topminnow

Huachuca water
umbel

Jaguar

Kearney blue star

Wednesday, May 17, 2006

SCIENTIFIC NAME

COMMON NAME

A herbaceous perennial
about 2 feet tall in the
dogbane family
(Apocynaceae). Thickened
woody root and many
pubescent (hairy) stems that
rarely branch. Flowers:
white terminal inflorescence
in April and May.

Endangered
Pima

Cochise, Santa
Cruz, Pima

Cochise, Pima,
Santa Cruz

Gila, Graham, La
Paz, Maricopa,
Pima, Pinal,
Santa Cruz,
Yavapai

Cochise, Gila,
Graham,
Greenlee,
Maricopa, Pima,
Pinal, Santa Cruz,
Yavapai

COUNTY

Pima County

Largest species of cat native
to Southwest. Muscular, with
relatively short, massive
limbs, and a deep-chested
body. Usually cinnamon-buff
in color with many black
spots. Weights ranges from
40-135 kg (90-300 lbs).

Herbaceous, semi-aquatic
perennial in the parsley
family (Umbelliferae) with
slender erect, hollow, leaves
that grow from the nodes of
creeping rhizomes. Flower:
3 to 10 flowered umbels
arise from root nodes.

Small (2 inches), guppy-like,
live bearing, lacks dark spots
on its fins. Breeding males
are jet black with yellow fins.

Deep compressed body, flat
head. Dark olive-gray color
above, silver sides. Endemic
to Gila River Basin.

DESCRIPTION

Endangered

Endangered

Endangered

Endangered

STATUS

HABITAT

3600-3800 ft

1,600 - >9,000
ft

3500-6500 ft

< 4,500 ft

Also occurs in New Mexico. A Jaguar
conservation team is being formed that is
being led by Arizona and New Mexico
state entities along with private
organizations.

Species also occurs in adjacent Sonora,
Mexico, west of the continental divide.
Critical habitat in Cochise and Santa Cruz
counties (64 FR 37441, July 12, 1999).

Species historically occurred in
backwaters of large rivers but is currently
isolated to small streams and springs.

Found on multiple private lands, including
the Nature Conservancy, the Audubon
Society, and others. Also occurs on
Federal and state lands and in Sonora,
Mexico. Critical habitat occurs in
Cochise, Gila, Graham, Greenlee, Pima,
Pinal, Santa Cruz and Yavapai counties.

COMMENTS

Page 2 of 5

West-facing drainages in
Plants grow in stable, partially shaded,
the Baboquivari Mountains. coarse alluvium along a dry wash in the
Baboquivari Mountains. Range is
extremely limited. Protected by Arizona
Native Plant Law.

Found in Sonoran
desertscrub up through
subalpine conifer forest.

Cienegas, perennial low
gradient streams,
wetlands.

Small streams, springs,
and cienegas vegetated
shallows.

2,000 - 5,500 ft Pools, springs, cienegas,
and streams.

ELEVATION

Cochise, Pima,
Santa Cruz

Pima, Pinal

Apache, Cochise,
Coconino, Gila,
Graham,
Greenlee,
Maricopa,
Mohave, Navajo,
Pima, Pinal,
Santa Cruz,
Yavapai

Pima

Cochise, Gila,
Graham,
Greenlee, Pima,
Pinal, Maricopa,
Santa Cruz

COUNTY

Pima County

Medium-sized spotted cat
whose tail is about 1/2 the
length of head and body.
Yellowish with black streaks
and stripes running from
front to back. Tail is spotted
and face is less heavily
streaked than the back and
sides.

Endangered

Leopardus (=Felis)
pardalis

Ocelot

Wednesday, May 17, 2006

Blue-green to yellowishgreen, columnar, 18 inches
tall, 8 inches in diameter.
Spine clusters have 5 radial
and 3 central spines; one
downward short; 2 spines
upward and red or vasally
gray. Flower: pink fruit:
woolly white.

Endangered

Medium sized with dark eyes
and no ear tufts. Brownish
and heavily spotted with
white or beige.

Males brick-red breast and
black head and throat.
Females are generally
nondescript but resemble
other races such as the
Texas bobwhite.

Echinocactus
horizonthalonius
var. nicholii

Endangered

Elongated muzzle, small leaf
nose, and long tongue.
Yellowish brown or gray
above and cinnamon brown
below. Tail minute and
appears to be lacking. Easily
disturbed.

Nichol Turk's head
cactus

Colinus virginianus
ridgewayi

Masked bobwhite

Endangered

DESCRIPTION

Threatened

Leptonycteris
curasoae
yerbabuenae

Lesser long-nosed
bat

STATUS

Mexican spotted owl Strix occidentalis
lucida

SCIENTIFIC NAME

COMMON NAME

< 8000 ft

2400-4100 ft

4100-9000 ft

1000-4000 ft

< 6000 ft

ELEVATION

Humid tropical and subtropical forests,
savannahs, and semi-arid
thornscrub.

Sonoran desertscrub.

Nests in canyons and
dense forests with multilayered foliage structure.

Desert grasslands with
diversity of dense native
grasses, forbs, and brush.

Desert scrub habitat with
agave and columnar cacti
present as food plants.

HABITAT

Page 3 of 5

May persist in partly-cleared forests,
second-growth woodland, and abandoned
cultivated areas reverted to brush.
Universal component is presence of
dense cover. Unconfirmed reports of
individuals in the southern part of the
State continue to be received.

Found in unshaded microsites in Sonoran
desertscrub on dissected alluvial fans at
the foot of limestone mountains and on
inclined terraces and saddles on
limestone mountain sides.

Generally nest in older forests of mixed
conifer or ponderosa pine/gambel oak
type, in canyons, and use variety of
habitats for foraging. Sites with cool
microclimates appear to be of importance
or are preferred. Critical habitat was
finalized on August 31, 2004 (69 FR
53182). Critical habitat in Arizona occurs
in Apache, Cochise, Coconino, Gila,
Graham, Greenlee, Maricopa, Navajo,
Pima, Pinal, Santa Cruz, and Yavapai
counties.

Species is closely associated with Acacia
angustissima. Formerly occurred in Altar
and Santa Cruz valleys, as well as
Sonora, Mexico. Presently only known
from reintroduced populations on Buenos
Aires NWR.

Day roosts in caves and abandoned
tunnels. Forages at night on nectar,
pollen, and fruit of paniculate agaves and
columnar cacti. This species is migratory
and is present in Arizona usually from
April to September and south of the
border the remainder of the year.

COMMENTS

Coryphantha
scheeri var.
robustispina

Antilocapra
americana
sonoriensis

Empidonax traillii
extimus

Echinomastus
erectocentrus var.
acunensis

Kinosternon
sonoriense
longifemorale

Pima pineapple
cactus

Sonoran pronghorn

Southwestern
willow flycatcher

Acuna cactus

Sonoyta mud turtle

Wednesday, May 17, 2006

SCIENTIFIC NAME

COMMON NAME

<12 inches high; spine
clusters borne on tubercles,
each with a groove on the
upper surface. 2-3 central
spines and 12 radial spines.
Flowers pink to purple.

Small passerine (about 6
inches) grayish-green back
and wings, whitish throat,
light olive-gray breast and
pale yellowish belly. Two
wingbars visible. Eye-ring
faint or absent.

Buff on back and white
below, hoofed with slightly
curved black horns having a
single prong. Smallest and
palest of the pronghorn
subspecies

Hemispherical stems 4-7
inches tall 3-4 inches
diameter. Central spine 1
inch long straw colored
hooked surrounded by 6-15
radial spines. Flower:
yellow, salmon, or rarely
white narrow floral tube..

DESCRIPTION

Candidate

Pima

Pima, Pinal

Apache, Cochise,
Coconino, Gila,
Graham,
Greenlee, La Paz,
Maricopa,
Mohave, Navajo,
Pima, Pinal,
Santa Cruz,
Yavapai, Yuma

Maricopa, Pima,
Yuma

Pima, Santa Cruz

COUNTY

Pima County

Primarily a pond turtle,
prefers mud or sandy
bottoms. Body 3 1/2 to 6 1/2
inches. Head and neck
mottled with contrasting light
and dark markings. Found in
Quitobaquito Springs.

Candidate

Endangered

Endangered

Endangered

STATUS

1,100 ft

1300-2000 ft

<8500 ft

500 - 2,000 ft

2300-5000 ft

ELEVATION

Ponds and streams.

Well drained knolls and
gravel ridges in Sonoran
desertscrub.

Cottonwood/willow and
tamarisk vegetation
communities along rivers
and streams.

Broad intermountain
alluvial valleys with
creosote-bursage and
palo verde-mixed cacti
associations.

Sonoran desertscrub or
semi-desert grassland
communities.

HABITAT

Page 4 of 5

Species also found in Rio Sonoyta,
Sonora, Mexico.

Immature plants distinctly different from
mature plants. They are disc-shaped or
spherical and have no central spines until
they are about 1.5 inches. Radial spines
are dirty white with maroon tips.

Migratory riparian-obligate species that
occupies breeding habitat from late April
to September. Distribution within its
range is restricted to riparian corridors.
Difficult to distinguish from other
members of the Empidonax complex by
sight alone. Training seminar required for
those conducting flycatcher surveys.
Critical habitat was finalized on October
19, 2005 (50 CFR 60886) and can be
viewed at http://arizonaes.fws.gov. In
Arizona there are critical habitat
segments in Apache, Cochise, Gila,
Graham, Greenlee, Maricopa, Mohave,
Pima, Pinal, and Yavapai counties.

Typically, bajadas are used as fawning
areas and sandy dune areas provide food
seasonally. Historical range was
probably larger than exists today. This
subspecies also occurs in Mexico.

Occurs in alluvial valleys or on hillsides in
rocky to sandy or silty soils. This species
can be confused with juvenile barrel
cactus (Ferocactus). However, the spines
of the later are flattened, in contrast with
the round cross-section of the Coryphanta
spines. 80-90% of individuals on state or
private land.

COMMENTS

SCIENTIFIC NAME

Sonorella eremita

San Xavier
talussnail

Wednesday, May 17, 2006

Allium gooddingii

Gooddings onion

Yellow-billed cuckoo Coccyzus
americanus

COMMON NAME

Conservation
Agreement

Conservation
Agreement

Candidate

STATUS

Pima

Apache,
Greenlee, Pima

Apache, Cochise,
Coconino, Gila,
Graham,
Greenlee, La Paz,
Maricopa,
Mohave, Navajo,
Pima, Pinal,
Santa Cruz,
Yavapai, Yuma

COUNTY

Pima County

Land snail, less than one
inch in diameter (about .75
inches), 4.5 whorls, round
shell, white to pinkish tint.

Herbaceous perenial plant;
broad, flat, rather blunt
leaves; flowering stalk 14-17
inches tall, flattened, and
narrowly winged toward
apex; fruit is broader than
long; seeds are short and
thick.

Medium-sized bird with a
slender, long-tailed profile,
slightly down-curved bill,
which is blue-black with
yellow on the lower half of
the bill. Plumage is grayishbrown above and white
below, with rufous primary
flight feathers.

DESCRIPTION

3,850-3,920 ft

> 7,500 ft

< 6,500 ft

ELEVATION

Deep, limestone rockslide
with outcrops of limestone
and decomposed granite.

Forested drainage
bottoms and on moist
north facing slopes of
mixed conifer and spruce
fir forests.

Large blocks of riparain
woodlands (cottonwood,
willow, or tamarisk
galleries).

HABITAT

Page 5 of 5

Conservation agreement signed by the
Service, Arizona Game and Fish
Department, El Paso Natural Gas
Company, and Arizona Electric Power
Cooperative, Inc. in September 1998.

Conservation agreement between the
Service and the Forest Service signed in
February 1998. In New Mexico on the
Lincoln and Gila National Forests.

Listing was found warranted, but
precluded as a distinct vertebrate
population segment in the western U.S.
on July 25, 2001. This finding indicates
that the Service has sufficient information
to list the bird, but other, higher priority
listing actions prevent the Service from
addressing the listing of the cuckoo at this
time.

COMMENTS

COMNAME
Felder's Orange Tip
Sonoran Pronghorn
Red-back Whiptail
Mexican Rosy Boa
Organ Pipe Shovel-nosed Snake
Western Yellow-billed Cuckoo
Quitobaquito Desert Pupfish
Acuna Cactus
Greater Western Bonneted Bat
Underwood's Bonneted Bat
Emory's Barrel-cactus
Great Plains Narrow-mouthed Toad
Cactus Ferruginous Pygmy-owl
Sonoran Desert Tortoise
Sonoyta Mud Turtle
Lesser Long-nosed Bat
Senita
California Leaf-nosed Bat
Thornber Fishhook Cactus
Cave Myotis
Pocketed Free-tailed Bat
Dahlia Rooted Cereus
Maricopa Leaf-nosed Snake
Yuma Clapper Rail
Organ Pipe Cactus
Quitobaquito Tryonia
Tumamoc Globeberry
Tropical Kingbird
SC

LE

SC

SC

SC
SC
C
LE

C
LE
C
SC
SC

LE
SC
SC

ESA

Arizona Game and Fish Department, Heritage Data Management System, May 7, 2007.

Designated Critical Habitat for the Quitobaquito Desert Pupfish within project area.

NAME
Anthocharis cethura
Antilocapra americana sonoriensis
Aspidoscelis burti xanthonota
Charina trivirgata trivirgata
Chionactis palarostris organica
Coccyzus americanus occidentalis
Cyprinodon eremus
Echinomastus erectocentrus var. acunensis
Eumops perotis californicus
Eumops underwoodi
Ferocactus emoryi
Gastrophryne olivacea
Glaucidium brasilianum cactorum
Gopherus agassizii (Sonoran Population)
Kinosternon sonoriense longifemorale
Leptonycteris curasoae yerbabuenae
Lophocereus schottii
Macrotus californicus
Mammillaria thornberi
Myotis velifer
Nyctinomops femorosaccus
Peniocereus striatus
Phyllorhynchus browni lucidus
Rallus longirostris yumanensis
Stenocereus thurberi
Tryonia quitobaquitae
Tumamoca macdougalii
Tyrannus melancholicus
S
S

S

S
S

S

S
S

S

SR
WSC

WSC
SR

SR

WSC
SR
WSC
SR

SR
WSC
WSC
WSC

USFS BLM STATE
S
S
WSC
S
S
S
S
WSC
WSC
HS

Special Status Species Documented within 5 Miles of the US/Mexico Border in the Organ
Pipe Cactus National Monument

APPENDIX C
Correspondence

United States Department of the Interior
U.S. Fish and Wildlife Service
2321 West Royal Palm Road, Suite 103
Phoenix, Arizona 85021-4951
Telephone: [phone] FAX: [phone]
In Reply Refer To:

AESO/SE
22410-2008-F-0011
February 11, 2008

Mr. George Hutchinson
U.S. Department of Homeland Security
Customs and Border Protection
1300 Pennsylvania Avenue NW
Room 3.4-D
Washington, D.C. 20229
RE: Biological Opinion for the Proposed Installation of 5.2 Miles of Primary Fence near
Lukeville, Arizona
Dear Mr. Hutchinson:
Thank you for your request for formal consultation with the U.S. Fish and Wildlife Service
(FWS) pursuant to section 7 of the Endangered Species Act of 1973 (16 U.S.C. 1531-1544), as
amended (Act). You requested initiation of formal consultation on September 17, 2007. At
issue are impacts that may result from your proposed primary fence project on Organ Pipe
Cactus National Monument in Pima County, Arizona. The proposed action may affect Sonoran
pronghorn (Antilocapra americana sonoriensis) and lesser long-nosed bats (Leptonycteris
curasoae yerbabuenae).
This biological opinion is based on information provided in the “Final Environmental
Assessment for the Proposed Installation of 5.2 Miles of Primary Fence near Lukeville, Arizona U.S. Border Patrol, Tucson Sector, November 2007” (EA) and other sources of information as
described in the consultation history. Literature cited in this biological opinion is not a complete
bibliography of all literature available on the species of concern; primary fence installation and
maintenance activities and their effects; road improvement and maintenance activities and their
effects; or on other subjects considered in this opinion. A complete administrative record of this
consultation is on file at the Phoenix, Arizona, Ecological Services Office (AESO).

Mr. George Hutchinson

2
CONSULTATION HISTORY

June 11, 2007: We received your 1 June 4, 2007, request for information on threatened or
endangered species, or those that are proposed to be listed as such under the Endangered
Species Act of 1973, as amended (Act), which may occur in your proposed project area.
July 10, 2007: We sent you a letter that included the aforementioned information you
requested as well as other recommendations to consider during the preparation of your
Environmental Assessment for the project.
September 17, 2007: We received your “Draft Environmental Assessment for the
Proposed Installation of 5.2 Miles of Primary Fence near Lukeville, Arizona - U.S.
Border Patrol, Tucson Sector, September 2007” and August 14, 2007, letter requesting
our concurrence that the Installation of 5.2 Miles of Primary Fence near Lukeville,
Border Patrol (BP) Tucson Sector Project, Pima County, Arizona (proposed project), may
affect, but is not likely to adversely affect, the federally endangered lesser long-nosed bat
and will have no effect on the endangered Sonoran pronghorn.
October 9, 2007: We held a conference call with Chris Ingram and Josh McEnany of
Gulf South Research Corporation (GSRC) to discuss the project’s effects on the Sonoran
pronghorn and lesser long-nosed bat. During the call, GSRC revised the determination
and concluded that the project may result in adverse effects to both species and that
formal section 7 consultation is warranted.
October 12, 2007: We received your electronic mail confirming the aforementioned
revision.
October 19, 2007: We sent you a letter initiating formal consultation. This letter also
included a request for information needed to complete our Biological Opinion.
December 3, 2007: We received an electronic mail from GSRC with the Final EA
attached.
December 19, 2007: We received your electronic mail inquiring about the status of our
Draft BO and informing us that the Final EA was submitted to our office. In a separate
electronic mail you stated that the Final EA addressed all requests in our October 19,
2007, letter. We sent you an electronic mail stating that the Final EA did not address all
of our requests, but that it contained enough information to start working on the
Biological Opinion. A conference call was scheduled for January 8, 2008, to discuss
outstanding information needs.
January 8 to February 5, 2007: We had numerous conference calls to discuss outstanding
concerns and information needs regarding your project. During these calls we agreed to a
1

For the purposes of this biological opinion, “your” and “you” means either Customs and Border Protection or the
Army Corps of Engineers.

Mr. George Hutchinson

3

number of conservation measures that are now incorporated into the “Description of the
Proposed Action” of this biological opinion.
February 6, 2008: We received your electronic mail providing the conservation measures
that CBP will implement as part of this project.
February 6, 2008: We sent you our draft biological opinion for the project.
BIOLOGICAL OPINION
DESCRIPTION OF PROPOSED ACTION
U.S. Customs and Border Protection (CBP) and U.S. Border Patrol (USBP) propose to construct
and maintain 5.2 miles of primary fence along the U.S.-Mexico border near Lukeville, Arizona
to help agents and officers gain effective control of the border. The proposed action,
summarized below, is described in detail in the “Final Environmental Assessment for the
Proposed Installation of 5.2 Miles of Primary Fence near Lukeville, Arizona - U.S. Border
Patrol, Tucson Sector, November 2007” (EA), as well as electronic mail correspondence from
Army Corps of Engineers (ACOE) and GSRC to FWS, and notes from conference calls with
CBP, ACOE, and GSRC. The project corridor (Figure 1) is within the Organ Pipe Cactus
National Monument (OPCNM) and encompasses 5.2 linear miles of the U.S. - Mexico border,
including 3.1 miles to the east and 2.1 miles to the west of the Lukeville Port of Entry (POE); the
project area is described in the Final EA.
Approximately 4.55 miles of primary fence will be installed approximately 6 feet north of the
U.S.-Mexico border on either side of the Lukeville POE and 3 feet north of the existing
Permanent Vehicle Barriers (PVBs). Approximately 0.65 mile of primary fence over Sonoyta
Hill (also known as Monument Hill) will be installed 3 feet north of the U.S.-Mexico border.
Construction activities associated with the installation of 4.55 miles of fence will occur entirely
within the 60-foot Roosevelt Reservation2 (RR); construction of the 0.65 mile of fence will
require a footprint of 150 feet, 90 feet beyond the RR.
The fence will made of 9-gauge mesh and though the final design will be developed by the
design/build contractor, at a minimum, it must extend 15 feet above ground and three to six feet
below ground; not impede the natural flow of water; and result only in minimal impacts on small
animal movements (see EA for a complete list of minimum fence requirements). Furthermore, in
most washes or arroyos, the fence will be designed and constructed to ensure proper conveyance
2

The 60-foot wide Roosevelt Reservation along the border was set aside from public use, with the exception of
public highways, as a protection against the smuggling of goods between the U.S. and Mexico by Presidential
Proclamation in 1907 by President Theodore Roosevelt. The Roosevelt Reservation includes all lands under Federal
ownership in California, Arizona and New Mexico at the time the proclamation was signed, creating a formal border
enforcement zone between the U.S. and Mexico (International Boundary Commission 1936).

Mr. George Hutchinson

4

of floodwaters and to eliminate the potential to cause backwater flooding on either side of the
U.S.-Mexico border. During rain events the USBP will be responsible for ensuring that debris
does not become wedged against the fence creating backwater flooding.
An existing patrol road that parallels the border for 4.55 miles of the project corridor will be used
for access during construction and subsequent maintenance of most of the fence (no
improvement to this portion of the road is proposed). To install and maintain primary fence over
Sonoyta Hill, west of the Lukeville POE, a new road will be constructed. The existing South
Puerto Blanco Road will be used for construction access and maintenance of the Sonoyta Hill
portion of the fence. Staging areas and turnarounds for the project will be located in previously
disturbed areas, within the RR, to minimize potential effects to the environment. Between 5.2
and 11.4 acre-feet (1.7 to 3.7 million gallons) of water for fence and road construction-related
activities will be required. All water will be trucked into the project site from sources north of
the OPCNM (i.e., Why, Ajo, or Gila Bend).
A total of about 45 acres (12 acres within the 150-foot wide footprint [this represents 5 acres
within the RR and 7 acres outside of the RR] and 33 acres within the 60-foot wide footprint) will
be permanently disturbed. About 17 acres of the total footprint have been previously disturbed
from the construction of the existing PVBs. Within the project footprint, up to 206 saguaros and
295 organ pipe cacti will be removed or salvaged (85 percent of these occur within the 0.65-mile
project corridor over Sonoyta Hill).
The road and fence will be maintained by the USBP on an as-needed basis to ensure the integrity
of the road and fence is not compromised. All project personnel will not exceed a speed limit of
25 miles per hour within OPCNM during construction and maintenance related activities
(excluding travel on Highway 85). The number of vehicles traveling to and from the project site
and the number of trips per day will be minimized to reduce the likelihood of disturbing
pronghorn in the area or injuring an animal on the road. The project is expected to be completed
by December 2008. Nighttime construction is not anticipated, however, it may occur.
CBP anticipates that the fence will facilitate increased border control within the 5.2-mile project
corridor. Therefore, the enforcement resources once used for security in that area will be more
available to respond to illegal activity on either side of the fence. Furthermore, CBP aims to
interdict illegal activity as close to the border as possible.
Conservation Measures
To reduce impacts to the environment, CBP and their representatives (i.e., ACOE, contractors,
and consultants) will implement a number of Environmental Design and Conservation Measures,
including: 1) demarcate the project area to be impacted before construction begins; 2)
implement a Stormwater Pollution Prevention Plan (SWPPP), including pre- and postconstruction Best Management Practices (BMPs) identified in the SWPPP; 3) implement erosion

Mr. George Hutchinson

5

control techniques; 4) construct the fence in arroyos in a way that ensures proper conveyance of
floodwaters and that eliminates the potential for backwater flooding on either side of the U.S.Mexico border; 5) remove debris from the fence immediately after rain events to ensure that no
backwater flooding occurs; 6) comply with the Migratory Bird Treaty Act; 7) check all
construction-related holes and trenches on a daily-basis and immediately remove and relocate all
animals that have fallen in the holes and trenches away from the site (>100 feet) (checking may
be done by anyone on-site; however, removal of animals will be done by a qualified biologist);
and 8) clean construction equipment prior to entering OPCNM to minimize the spread and
establishment of non-native and invasive species. A biological monitor will be on-site daily to
ensure project compliance (i.e., ensure contractors are staying within the demarcated impact
area; move animals, such as desert tortoise, out of the project corridor; etc.). When contractors
are working on the western slope of Sonoyta Hill, the biological monitor will conduct surveys for
Sonoran pronghorn as close to dawn as possible. If Sonoran pronghorn are detected within 0.62
mile of project activities, no project work will begin until pronghorn move on their own volition
to a distance greater than 0.62 mile from the activities. All contractors, work crews (including
National Guard and military personnel), and CBP personnel in the field performing construction
and maintenance activities would receive training on the habitat and habits of species found in
the project area, including information on how to avoid impacts to the species from their
activities.
To help offset impacts to lesser long-nosed bat foraging habitat and other natural resources, CBP
and their representatives will (or provide funding for): 1) in close coordination with OPCNM,
salvage all columnar cacti less than three feet tall to the extent practicable (approximately 74
saguaro and 68 organ pipe cacti 3 ) and attempt to salvage columnar cacti between three and six
feet (approximately 41 saguaro and 55 organ pipe cacti3) that face danger of destruction within
the project corridor as determined by the biological monitor and that have been identified using
GPS-technology (either by GSRC or OPCNM), as well as about 20 barrel cacti; 2) transport the
salvaged cacti to an area, likely the OPCNM nursery, where they will be temporarily planted in
prepared beds; 3) care for them until they are ready to be replanted; and 4) replant (water and
monitor) them in areas to be restored within OPCNM (as identified in the restoration plan-see
below). The contractor responsible for constructing the fence will also be responsible for cactus
salvage and transportation, as well as care until funds become available through the
programmatic mitigation agreement (explained below). Non-salvageable plants destroyed in the
project corridor and not needed for on-site erosion control or restoration, as determined by an
erosion-control/restoration specialist and OPCNM staff, will be hauled away to an appropriate
disposal site outside of OPCNM.

3

During a recent survey (February 2008), OPCNM staff counted a total of 140 salvageable saguaros and 112
salvageable organ pipe cacti. These numbers differ from those provided by GSRC; however, regardless of the exact
number, all saguaros and organ pipe determined to be salvageable within the project footprint will be salvaged.

Mr. George Hutchinson

6

To help offset impacts to lesser long-nosed bats, Sonoran pronghorn, and other natural resources
CBP will provide funding in the amount of $955,000.00 4 to restore 84 acres (to be identified by
OPCNM personnel) within OPCNM, including illegal roads and trails within the Monument.
We anticipate that about 60 percent of the restoration will benefit the conservation of the lesser
long-nosed bat and about 40 percent will benefit the Sonoran pronghorn. A restoration plan will
be developed and implemented by a qualified Sonoran Desert restoration specialist, in close
coordination with OPCNM. Development of the plan will be the responsibility of the fence
contractor, however, implementation of it will be the responsibility of DOI. The plan will be
completed within 6 months of the issuance of the biological opinion and, among other
components, will include replanting, watering as needed, and monitoring the success of salvaged
cacti; eradication of non-native invasive species; and general maintenance and monitoring of the
restoration areas for 5 years. No restoration will occur within the project footprint, as the area
will be needed for future CBP operations; however, non-native invasive plants will be monitored
and controlled in the area for three years.
To aid in the conservation and recovery of pronghorn and to help offset potential impacts to
pronghorn that may occur as a result of this project, the CBP will provide funding to the FWS to
fill a Sonoran pronghorn water for 10 years at a cost per year of $2,500.00 (for a total of
$25,000).
The aforementioned funding ($955,000 and $25,000) will be incorporated within a programmatic
mitigation agreement between Department of Homeland Security/CBP and Department of the
Interior (DOI)/FWS. Once funding is provided to DOI through this agreement, DOI will be
responsible for implementing the restoration plan and filling the Sonoran pronghorn water.
SONORAN PRONGHORN
STATUS OF THE SPECIES
A. Description, Legal Status, and Recovery Planning
The Sonoran subspecies of pronghorn (Antilocapra americana sonoriensis) was first described
by Goldman (1945) and is the smallest of the five subspecies of pronghorn (Nowak and Paradiso
1983). The subspecies was listed throughout its range as endangered on March 11, 1967 (32 FR
4001) under the Endangered Species Preservation Act of October 15, 1966 without critical
habitat. Three sub-populations of the Sonoran pronghorn are extant: 1) a U.S. sub-population in
southwestern Arizona, 2) a sub-population in the Pinacate Region of northwestern Sonora, and 3)
a sub-population on the Gulf of California west and north of Caborca, Sonora. The three subpopulations are geographically isolated due to barriers such as roads and fences, and in the case
of the two Sonora sub-populations, by distance.
4

These funds will also be used to pay for the care of salvaged cactus at the temporary holding facility until they are
ready to be replanted. If the salvage occurs before the funds are available, the salvaged cactus will be cared for by
CBP or their representatives until the funds become available.

Mr. George Hutchinson

7

The 1982 Sonoran Pronghorn Recovery Plan (U.S. Fish and Wildlife Service 1982) was revised
in 1998 (U.S. Fish and Wildlife Service 1998). The recovery criteria presented in the revised
plan entailed the establishment of a population of 300 adult pronghorn in one self-sustaining
population for a minimum of five years, as well as the establishment of at least one other selfsustaining population in the U.S. to reclassify the subspecies to threatened. Actions identified as
necessary to achieve these goals include the following: 1) enhance present sub-populations of
pronghorn by providing supplemental forage and/or water; 2) determine habitat needs and
protect present range; 3) investigate and address potential barriers to expansion of presently used
range and investigate, evaluate, and prioritize present and potential future reintroduction sites
within historical range; 4) establish and monitor a new, separate herd(s) to guard against
catastrophes decimating the core population, and investigate captive breeding; 5) continue
monitoring sub-populations and maintain a protocol for a repeatable and comparable survey
technique; and 6) examine additional specimen evidence available to assist in verification of
taxonomic status. In 2001 a supplement and amendment to the 1998 Final Revised Sonoran
Pronghorn Recovery Plan was prepared (U.S. Fish and Wildlife Service 2001). We concluded
that data do not yet exist to support establishing delisting criteria. Tasks necessary to accomplish
reclassification to threatened status (as outlined in the 1998 plan) should provide the information
necessary to determine if and when delisting will be possible and what the criteria should be.
B. Life History and Habitat
Sonoran pronghorn inhabit one of the hottest and driest portions of the Sonoran Desert. They
forage on a large variety of perennial and annual plant species (Hughes and Smith 1990, Hervert
et al. 1997b, U.S. Fish and Wildlife Service 1998). During drought years, Hughes and Smith
(1990) reported cacti were the major dietary component (44 percent). Consumption of cacti,
especially chain fruit cholla (Cylindropuntia fulgida, Pinkava 1999), provides a source of water
during hot, dry conditions (Hervert et al. 1997b). Other important plant species in the diet of the
pronghorn include pigweed (Amaranthus palmeri), ragweed (Ambrosia sp.), locoweed
(Astragalus sp.), brome (Bromus sp.), and snakeweed (Gutierrezia sarothrae) (U.S. Fish and
Wildlife Service1998). Pronghorn will move in response to spatial limitations in forage
availability (Hervert et al. 1997a). Water intake from forage is not adequate to meet minimum
water requirements (Fox et al. 2000), hence pronghorn need and readily use both natural and
artificial water sources (Morgart et al. 2005).
Sonoran pronghorn rut during July-September, and does have been observed with newborn
fawns from February through May. Parturition corresponds with annual spring forage
abundance. Fawning areas have been documented in the Mohawk Dunes and the bajadas of the
Sierra Pinta, Mohawk, Bates, Growler, and Puerto Blanco mountains. Does usually have twins,
and fawns suckle for about 2 months. Does gather with fawns, and fawns sometimes form
nursery groups (U.S. Fish and Wildlife Service 1998). Sonoran pronghorn form small herds of
up to 21 animals (Wright and deVos 1986).

Mr. George Hutchinson

8

Telemetry locations of 35 Sonoran pronghorn demonstrated that during 1995-2002, pronghorn
used creosote/bursage and palo verde/mixed cactus vegetation associations less than expected or
equal to availability. Pronghorn use of palo verde/chain fruit cholla associations and desert
washes occurred more than expected. However, during the cool and wet winter on 1997-1998,
pronghorn were found in creosote/bursage associations more than expected (Hervert et al. 2005).
In contrast, during 1983-1991, pronghorn used creosote/bursage and palo verde mixed cacti
associations more than expected (deVos and Miller 2005). Differences between these study
results may be due in part to differences in precipitation and forage patterns between these
periods. The earlier period was wetter with greater forage availability in flats and valleys where
creosote/bursage associations predominate. In wet winters and early spring pronghorn are often
found in flats and valleys, such as Pinta Sands, the Mohawk Dunes west of the Mohawk
Mountains, and the west side of the Aguila Mountains. In late spring and summer, pronghorn
then move from the flats and valleys upslope into bajadas and often south or southeast where
palo verde associations, chain fruit cholla, and washes are more common. Movements are most
likely motivated by the need for thermal cover provided by leguminous trees and water available
in succulent chain fruit cholla (Hervert et al. 1997b. Home range size of Sonoran pronghorn
during 1995-2002 ranged from 16.6 to 1,109 mi2, with an average of 197 + 257 mi2 (Hervert et
al. 2005).
From 1995-2002, adult mortality rates varied from 11-83%. Adults were killed by coyotes,
bobcats, mountain lions, capturing efforts, drought, and unknown causes (Bright and Hervert
2005). However, during 1983-1991, apparently a more favorable period for pronghorn during
which the population grew significantly, mean annual survival of females and males was 96% +
0.04 and 92% + 0.04 (DeVos and Miller 2005). Disease may affect mortality, but has not been
thoroughly investigated (Bright and Hervert 2005). Hervert et al. (2000) found that the number
of fawns surviving until the first summer rains was significantly correlated to the amount of
preceding winter rainfall, and negatively correlated to the number of days without rain between
the last winter rain and the first summer rain. Drought may be a major factor in the survival of
adults and fawns (Bright and Hervert 2005). Three radio-collared pronghorn died in July and
August of 2002 with no obvious cause of death. Given that 2002 was one of the driest years on
record, the proximate cause of these mortalities was likely heat stress and/or malnutrition
resulting from inadequate forage conditions due to drought.
C. Distribution and Abundance
United States
Historically, the Sonoran pronghorn ranged in the U.S. from approximately the Santa Cruz River
in the east, to the Gila Bend and Kofa Mountains to the north, and to Imperial Valley, California,
to the west (Mearns 1907, Nelson 1925, Monson 1968, Wright and deVos 1986, Paradiso and
Nowak 1971; Figure 2). Bright et al. (2001) defined the present U.S. range of the Sonoran
pronghorn as bordered by Interstate 8 to the north, the International Border to the south, the
Copper and Cabeza mountains to the west, and SR 85 to the east (see Figure 3). This area
encompasses 2,508 mi2 (Bright et al. 2001).

Mr. George Hutchinson

9

While Mearns (1907) suggested that pronghorn may have been common in some areas in the late
1800s, evidence suggests that the sub-population declined dramatically in the early 20th century.
Sub-population estimates for Arizona, which only began in 1925, have never shown the
pronghorn to be abundant (Table 1). Repeatable, systematic surveys were not conducted in
Arizona until 1992. Since 1992, Sonoran pronghorn in the United States have been surveyed
biennially (Bright et al. 1999, 2001) using aerial line transects (Johnson et al. 1991). Subpopulation estimates from these transects have been derived using three different estimators
(Table 2); currently the sightability model (Samuel and Pollock 1981) is considered the most
reliable estimator (Bright et al. 1999, 2001). Table 2 presents observation data from transects
and compares estimates derived from the three population models from 1992 through 2006.
The sightability model population estimates from 1992 to 2000 showed a 45 percent decrease in
sub-population size (Table 2). The estimates indicate a steady decline in sub-population size,
with the exception of the 1994 survey. The 1994 estimate may be somewhat inflated due to
inconsistencies in survey timing (U.S. Fish and Wildlife Service 1998, Bright et al. 2001).
High fawn mortality in 1995 and 1996 and the death of half (8 of 16) of the adult, radio-collared
pronghorn during the 13 months preceding the December 1996 survey corresponded to five
consecutive six-month seasons of below normal precipitation (summer 1994 through summer
1996) throughout most of the Sonoran pronghorn range, which likely contributed, in part, to
observed mortality (Bright et al. 2001, Hervert et al. 1997b).
Mortality of Sonoran pronghorn in 2002 was exceptionally high (Bright and Hervert 2005). At
the start of the year, seven radio-collared Sonoran pronghorn were at large in the U.S. subpopulation. By December 2002, all but one of these had died. For most, drought stress was
considered to be the proximate cause. For those animals that may have succumbed to predation,
it was suspected that drought stress was again a factor, by making the animal more vulnerable to
predation, due to an emaciated physical condition and being forced into predator habitats by
drought. The 2002 drought was one of the driest on record. As an example, annual rainfall at
the OPCNM visitor center was only 2.54 inches in 2002 (T. Tibbitts, Organ Pipe Cactus NM,
pers. comm. 2002); average annual rainfall for the visitor center is 9.2 inches (Brown 1982).
The November/December 2002 population survey revealed the U.S. sub-population had declined
to the lowest level ever recorded. A total of 18 pronghorn were observed, in three groups (8, 9,
and 1). The sightability model resulted in a population estimate of 21 animals, or a 79% decline
from 2000. Also, very few fawns survived in 2002 to replace these dying adults.
Although drought was likely the proximate cause of the dramatic decline of the U.S. subpopulation in 2002, anthropogenic factors almost certainly contributed to or exacerbated the
effects of the drought. Historically, pronghorn likely moved to wetted areas and foraged along
the Rio Sonoyta, Sonora, and the Gila and probably Colorado rivers during drought. These areas
are no longer accessible to the U.S. population due to fences, Interstate 8, Mexico Highway 2,
and other barriers. The rate of decline in the U.S. sub-population from 2000-2002 (79 percent)
was also much greater than that observed in either the sub-population southeast of Highway 8
(18 percent decline) or the El Pinacate sub-population (26 percent) during the same period (see
discussion of Mexican sub-populations in the next section). Observations of forage availability

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suggest the El Pinacate sub-population experienced the same severe drought that occurred on the
Arizona side (T. Tibbitts, J. Morgart, pers. comm. 2003). Yet that sub-population fared much
better than its U.S. counterpart. The high level of human activities and disturbance on the U.S.
side, particularly in regard to undocumented alien traffic, smugglers, and required law
enforcement response, as compared to what occurs in the El Pinacate area, is a likely
contributing factor in the differing rates of decline observed north and south of the border. See
the section entitled “Drought” in the Environmental Baseline and “Cumulative Effects” for
further discussion.
The December 2004 survey resulted in an estimated 58 wild pronghorn in the U.S. subpopulation, a substantial increase brought on by favorable conditions since 2002. Based on
casual surveys and estimated fawn survival, the population in 2005 was roughly 75 wild
pronghorn. Based on a December 2006 aerial survey, the U.S. sub-population was estimated at
68 (Table 2). Based, again, on casual surveys as well as aerial tracking of ten telemetered
pronghorn, the 2007 wild population is now estimated at about 70.
Semi-captive breeding facility
As part of a comprehensive emergency recovery program, adult pronghorn were first captured
and placed into a semi-captive breeding facility at CPNWR in 2004. There are currently (as of
January 2008) 37 pronghorn in the enclosure. Two yearling bucks were released from the pen
into the wild herd in November 2006, and another two were released in January 2007. The
objective is to produce 10-25 fawns each year to be released into the U.S. sub-population, and
potentially to establish a second U.S. sub-population at Kofa NWR. Planning for the second
herd is underway. Various alternatives are being considered, but a second herd could be
established in King Valley of Kofa NWR within five years. A captive facility with a forage
enhancement plot, and development of waters in King Valley would likely be needed. The
population would probably be introduced as an experimental, nonessential population under
section 10(j) of the Act.
Mexico
Historically, Sonoran pronghorn ranged in Sonora from the Arizona border south to Hermosillo
and Kino Bay, west to at least the Sierra del Rosario, and east to the area south of the
Baboquivari Valley on the Tohono O’odham Nation (Nelson 1925, Carr 1974, Monson 1968).
The distribution in Baja California Norte is less clear, but observations by Mearns (1907)
indicate they occurred in the Colorado Desert west of the Colorado River, as well. Sonoran
pronghorn are currently extant in two sub-populations in Mexico, including: (1) Pinacate subpopulation west of Highway 8 near the Pinacate Lava flow; and (2) north and west of Caborca
and southeast of Highway 8.
Sub-populations of Sonoran pronghorn in Sonora had not been thoroughly surveyed until the
December 2000 surveys (Bright et al. 2001), at which time 346 pronghorn were estimated to
occur in Sonora. Although the 1993 estimate was approximate, survey results suggested a
decline in the sub-populations of 16 percent from 1993 to 2000 (Table 3). The two Mexico subpopulations were resurveyed in December 2002. A grand total (both El Pinacate and southeast

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of Highway 8) of 214 pronghorn in 32 groups were seen for a tentative population estimate of
280, indicating further decline. Only 19 pronghorn were observed in the Pinacate area for an
estimate of 25, which is a decline of 26% from the 2000 estimate. Surveys conducted in
December 2004 and February 2005 demonstrated that the population southeast of Highway 8
increased to 625 (439 observed), while the Pinacate population increased to 59 (30 observed). In
January 2006, surveys indicated that pronghorn numbers are remaining steady with an estimated
total of 634 (486 observed) individuals (combined for both populations). Nine of these were
captured, of which five were fitted with radio-collars and released and four were transferred to
the semi-captive breeding facility in the U.S.
Population Viability Analysis
In 1996, a workshop was held in which a population viability analysis (PVA) was conducted for
the U.S. sub-population of Sonoran pronghorn (Defenders of Wildlife 1998). A PVA is a
structured, systematic, and comprehensive examination of the interacting factors that place a
population or species at risk (Gilpin and Soulé 1986). Based on the best estimates of
demographic parameters at the time, the likelihood of extinction of Sonoran pronghorn was
calculated as one percent in the next 25 years, nine percent in the next 50 years, and 23 percent
in the next 100 years. More severe threats include population fluctuation, periodic decimation
during drought (especially of fawns), small present population size, limited habitat preventing
expansion to a more secure population size, and expected future inbreeding depression. At
populations of less than 100, population viability declined at an increasingly steep rate. To
maintain genetic diversity over the long term, a population of at least 500 is desirable (Defenders
of Wildlife 1998). The likelihood of extinction increased markedly when fawn mortality
exceeded 70 percent. Thus, a 30 percent fawn crop (30 fawns/100 does) each year is necessary
to ensure the continuance of the U.S. sub-population. The authors concluded that “this
population of the Sonoran pronghorn, the only one in the U.S., is at serious risk of extinction.”
The authors made these conclusions prior to the severe drought and decline in the species in
2002. On the other hand, Hosack et al. (2002) found that some management actions were
possible that could improve the chances of population persistence significantly. Actions that
would ameliorate the effects of drought or minimize mortality of pronghorn were of particular
importance for improving population persistence.
E. Threats
Barriers that Limit Distribution and Movement
Highways, fences, railroads, developed areas, and irrigation canals can block access to essential
forage or water resources. Highways 2 and 8 in Sonora, and SR 85 between Gila Bend and
Lukeville, Arizona support a considerable amount of fast-moving vehicular traffic, and are
fenced in some areas, and are likely a substantial barrier to Sonoran pronghorn. Interstate 8, the
Wellton-Mohawk Canal, agriculture, a railroad, and associated fences and human disturbance
near the Gila River act as barriers for northward movement of pronghorn. De-watering of
reaches of the Río Sonoyta and lower Gila River, and barriers to pronghorn accessing the Gila
River, such as Interstate 8 and the Wellton-Mohawk Canal, have caused significant loss of
habitat and loss of access to water (Wright and deVos 1986). Agricultural, urban, and

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commercial development at Sonoyta, Puerto Peñasco, and San Luis Río Colorado, Sonora; in the
Mexicali Valley, Baja California Norte; and at Ajo, Yuma, and along the Gila River, Arizona,
have further removed habitat and created barriers to movement.
Human-caused Disturbance
A variety of human activities occur throughout the range of the pronghorn that have the potential
to disturb pronghorn or its habitat, including livestock grazing in the U.S. and Mexico; military
activities; recreation; poaching and hunting; clearing of desert scrub and planting of buffelgrass
(Pennisetum ciliare) in Sonora; gold mining southeast of Sonoyta, dewatering and development
along the Gila River and Río Sonoyta; increasing undocumented immigration and drug
trafficking across the international border and associated required law enforcement response; and
roads, fences, canals, and other artificial barriers.
Studies of captive pronghorn, other than the Sonoran subspecies, have shown that they are
sensitive to disturbance such as human presence and vehicular noise. Human traffic, such as a
person walking or running past pronghorn in an enclosed pen, a motorcycle driving past, a truck
driving past, a truck blowing its horn while driving past, or a person entering a holding pen,
caused an increased heart-rate response in American pronghorn in half-acre holding pens
(Workman et al. 1992). The highest heart rates occurred in female pronghorn in response to a
person entering a holding pen, or a truck driving past while sounding the horn. The lowest heart
rates occurred when a motorcycle or truck was driven past their pen. Pronghorn were more
sensitive to helicopters, particularly those flying at low levels or hovering, than fixed wing
aircraft. Other investigators have shown that heart rate increases in response to auditory or
visual disturbance in the absence of overt behavioral changes (Thompson et al. 1968,
Cherkovich and Tatoyan 1973, Moen et al. 1978). Hughes and Smith (1990) found that
pronghorn immediately ran 1,310-1,650 feet from a vehicle. Krausman et al. (2001, 2004,
2005a) examined effects of military aircraft and ground-based activities on Sonoran pronghorn at
the North and South TACs on the Barry M. Goldwater Range (BMGR) and concluded that
military activities, both ground-based and aerial, were associated with some changes in behavior
(e.g., from standing to trotting or running, or bedded to standing) but the authors concluded that
these changes were not likely to be detrimental to the animals. Sightings of pronghorn were
biased towards disturbed habitats on the TACs and other areas of military activities, which also
corresponded to areas of favorable ephemeral forage production (Krausman et al. 2005a). No
conclusions could be drawn about effects of military activities on fawns due to poor fawn
productivity during the Krausman et al. study. During times of drought, disturbances that cause
pronghorns to startle and run would energetically have a more significant effect. Such energetic
expenditures, particularly during times of stress, may lead to lower reproductive output and/or
survival of individual animals (Geist 1971).
Habitat Disturbance
Livestock grazing has the potential to significantly alter pronghorn habitat and behavior
(Leftwich and Simpson 1978, Kindschy et al. 1982, Yoakum et al. 1996). Overgrazing well into
the 19th century by Spaniards and their descendants caused widespread habitat changes
throughout much of the Sonoran Desert, particularly in more settled areas such as central Sonora,

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Mexico (Sheridan 2000). The effects of cattle grazing are largely historical; cattle were removed
from OPCNM, CPNWR, and the BMGR in 1979, 1983, and 1986, respectively (U.S. Fish and
Wildlife Service 1998, Rutman 1997). In 2004, the Bureau of Land Management (BLM) closed
the Cameron Allotment on the borders of CPNWR and OPCNM, but grazing still occurs in the
nearby Childs and Coyote Flat allotments near Ajo. In Sonora, livestock grazing occurs at Pozo
Nuevo and at Ejido Puerto Peñasco, but cattle typically stay close to feed and water except in
seasons with abundant annual growth when cattle range widely in the Pinacate region.
Mining occurred historically throughout much of the U.S. range of the pronghorn, but is
currently not a significant threat to Sonoran pronghorn in the U.S. During recent pronghorn
surveys in Mexico, increasing effects from gold mining activities were noted in habitats used by
the sub-population located southeast of Highway 8.
Illegal crossings by undocumented immigrants and drug smugglers in the U.S. range of the
pronghorn have increased dramatically in recent years. In 2001, estimates of undocumented
migrants traffic reached 1,000 per night in OPCNM alone (Organ Pipe Cactus National
Monument 2001), and an estimated 150,000 people entered the monument illegally from Mexico
(Milstead and Barns 2002). Apprehensions of illegal immigrants and smugglers by the Ajo
Station of the Tucson USBP Sector increased from increased 2837 in 1997 to 6327 in 2005
(personal communication with David BeMiller, February 10, 2006). From October 2005 to
February 2006, 6908 apprehensions were made by the Ajo Station (personal communication with
David BeMiller, February 10, 2006). The Wellton Station of the Yuma USBP Sector made 2080
apprehensions in fiscal year 2005 and 3339 apprehensions from October 2005 to February 2006
(personal communication with David BeMiller, February 10, 2006). USBP agents have
indicated, however, that apprehensions have recently decreased due to USBP presence at Camp
Grip (electronic mail from David Guzewich, February 8, 2008). Illegal border-related activities
and required USBP response have resulted in widespread habitat degradation and increased
human presence in remote areas. For instance, all the valleys at Cabeza Prieta NWR are now
criss-crossed with a network of north-south roads and trails, even though those areas are
designated as wilderness. Illegal immigrants and smugglers have shifted their activities to more
remote areas, including Sonoran pronghorn habitat in southwestern Arizona, as USBP has been
able to successfully gain control of more urban areas. There is anecdotal evidence that
pronghorn are avoiding areas of high illegal traffic and law enforcement activities (personal
communication with Curtis McCasland, CPNWR, 2007).
Fire
The winter and spring of 2004/2005 were very wet, resulting in some of the highest productivity
of cool season annual plants in recent memory. As these annual plants dried out, they created
fuel for wildfire. In 2005, Mediterranean grass combined with high densities of the native wooly
plantain (Plantago ovata) and other species created fuels adequate to carry fire. Military
training, such as strafing and bombing in the tactical ranges, as well as fires set by illegal
immigrants or smugglers, provided the ignition sources. Exact numbers are unknown; however,
in 2005 roughly 7,500 acres of pronghorn habitat burned on the CPNWR (personal
communication with Curtis McCasland, CPNWR, February 15, 2006) and more than 63,000

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acres burned on the BMGR-East during that time. Approximately 29,260 acres of pronghorn
habitat were consumed as a result of these fires.
Most Sonoran Desert trees, shrubs, and cacti are poorly adapted to fire (Brown and Minnich
1986, Schwalbe et al. 2000, Alford and Brock 2002). If areas burn repeatedly, permanent
changes are likely in the flora. Even in the best scenario it is likely to be many years before trees
once again provide thermal cover in wash communities and cholla recover to a point that they are
useful forage plants for pronghorn. In 2007, pronghorn were attracted to the burned areas,
which often supported better growth of annual plants and forbs than adjacent unburned areas.
However, in the long term and if these areas continue to burn, removal of thermal cover (trees)
and chain fruit cholla, which they depend on in drought, would likely adversely affect pronghorn
and probably limit the use of these areas to wetter and cooler periods and seasons.
Drought
As discussed, drought may be a major factor in the survival of adults and fawns (Bright and
Hervert 2005), and the major decline in 2002 was driven by drought. Mean annual temperatures
rose 2.0-3.1 0F in the American Southwest in the 20th century, and are predicted to rise 8.1-11.0
0
F in the 21st century. Most of the observed increases in globally averaged temperatures since
the mid-20th century are very likely due to the observed increases in anthropogenic greenhouse
gas concentrations (Intergovernmental Panel on Climate Change 2007). In the Sonoran Desert,
anthropogenic climate change is causing warming trends in winter and spring, decreased
frequency of freezing temperatures, lengthening of the freeze-free season, and increased
minimum temperatures in winter, which will likely cause changes in vegetation communities
(Weiss and Overpeck 2005). These increases in temperature are predicted to be accompanied by
a more arid climate in the Southwest (Seager et al. 2007, Intergovernmental Panel on Climate
Change 2007). As a result, the Sonoran pronghorn is expected to be confronted with more
frequent drought, which increases the importance of recovery actions, such as forage
enhancement plots and water developments, which can offset the effects of drought.
Small Population Size and Random Changes in Demographics
At populations of less than 100, population viability declines at an increasingly steep rate. To
maintain genetic diversity over the long term, a population of at least 500 is desirable (Defenders
of Wildlife 1998). At an estimated 21 in 2002, and roughly 70 wild pronghorn in 2007, the U.S.
sub-population is critically endangered and is going through a genetic bottleneck. At an
estimated 25 in 2002 and 59 in 2004, the Pinacate sub-population is also well below desired
numbers. At 625, the third sub-population (southeast of Highway 8) is marginally large enough
to maintain genetic diversity. Loss of the U.S. sub-population would dramatically reduce our
ability to manage or recover this subspecies. Populations at low levels may experience random
variations in sex ratios, age distributions, and birth and death rates among individuals, which can
cause fluctuations in population size and possibly extinction (Richter-Dyn and Goel 1972). In
very sparse populations, males may have trouble finding females, reducing productivity (Ehrlich
and Roughgarden 1987). Small populations are also sensitive to variations in natural processes,
such as drought and predation (Hecht and Nickerson 1999).

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Disease
Sonoran pronghorn can potentially be infected by a variety of viral and bacterial diseases.
Blood testing has shown pronghorn exposure to these diseases by increases in antibody titers
over time. The diseases relevant to pronghorn can be transmitted indirectly through vectors,
such as infected midges or ticks, or directly via aerosolized or direct contact of infected fluids or
tissues. Diseases that potentially infect pronghorn are all serious diseases of cattle, which can act
as vectors. Cattle within the current range of the pronghorn have not been tested for these
diseases.
ENVIRONMENTAL BASELINE
The environmental baseline includes past and present impacts of all Federal, state, or private
actions in the action area; the anticipated impacts of all proposed Federal actions in the action
area that have undergone formal or early section 7 consultation; and the impact of state and
private actions which are contemporaneous with the consultation process. The environmental
baseline defines the current status of the species and its habitat in the action area to provide a
platform from which to assess the effects of the action now under consultation.
A. Action Area
The “action area” means all areas to be affected directly or indirectly by the Federal action and
not merely the immediate area involved in the action. Within the U.S. portion of the Sonoran
pronghorn’s range, pronghorn interact to form one sub-population in which interbreeding may
occur. The U.S. sub-population is effectively separated from sub-populations in the El Pinacate
Region and on the Gulf Coast of Sonora by Mexico Highways 2 and 8. Activities that may
affect animals in any portion of the U.S. range of the pronghorn may affect the size or structure
of the U.S. sub-population, or habitat use within the U.S. range. The action area for this
biological opinion is defined as the current range of the pronghorn within the U.S. (Figure 3),
plus areas along the border 3.1 miles to the east and 2.1 miles to the west of the Lukeville POE.
Management of the action area is almost entirely by Federal agencies. The BMGR (roughly 1.6
million acres) is managed by Luke Air Force Base and MCAS-Yuma primarily for military
training. OPCNM manages 329,000 acres in the southeastern corner of the action area for
scenic, ecological, natural, and cultural values. CPNWR lies along the border west of OPCNM
and encompasses 860,000 acres. CPNWR is managed to protect, maintain, and restore the
diversity of the Sonoran Desert. Most of the refuge and OPCNM are designated as wilderness.
The BLM manages lands near Ajo for recreation, grazing, and other multiple uses in accordance
with the Lower Gila Resource Management Plan. OPCNM and CPNWR are critically important
for Sonoran pronghorn recovery because of their management for protection of natural resources.
Lands on the BMGR are managed primarily for military training, and although important
recovery is ongoing on these lands and the Department of Defense has generously contributed to
the recovery program both on and off the BMGR, changing military priorities could, in the
future, limit the value of the BMGR for Sonoran pronghorn recovery.

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B. Terrain, Vegetation Communities, and Climate in the Action Area
The action area is characterized by broad alluvial valleys separated by block-faulted mountains
and surface volcanics. The Yuma Desert on the western edge of the BMGR is part of a broad
valley that includes the Colorado River. Major drainages and mountain ranges run northwest to
southeast. Major drainages flow mostly northward to the Gila River, although southern portions
of OPCNM and the southern slope of the Agua Dulce Mountains drain south to the Río Sonoyta.
Climate is characterized by extreme aridity, mild winters, and hot summers. Approximately 2.7
inches of precipitation fall annually at Yuma, with slightly more than half of this occurring in the
winter months (Brown 1982). Annual precipitation increases from west to east across the
BMGR; at Aguajita/Quitobaquito, precipitation is 10.5 inches annually.
The vegetation community of the western portion of the BMGR has been classified as the lower
Colorado River Valley subdivision of Sonoran Desert scrub (Brown 1982). It is the largest and
most arid subdivision of Sonoran Desert scrub. The Arizona Upland subdivision of Sonoran
Desert scrub is found in the Growler, Puerto Blanco, Ajo and Bates mountains, and surrounding
bajadas.
C. Status of the Sonoran Pronghorn in the Action Area
Distribution, Abundance, and Life History
The distribution and abundance of the Sonoran pronghorn in the action area is the same as that
described above in the Status of the Species for the U.S. sub-population. Life history, including
demographics, chronology of breeding and movements, diet, and other factors were also
described above for the U.S. population.
Drought
As discussed in the Status of the Species, anthropogenic climate change in the Southwest and the
Sonoran Desert is predicted to result in warming trends and drier conditions, with accompanying
changes in vegetation communities (Weiss and Overpeck 2005, Seager et al. 2007). Rowlands
(2000) examined trends in precipitation for southwestern Arizona and OPCNM from 1895-1999.
For southwestern Arizona, no trend in precipitation was found for the period, but low
precipitation occurred around 1895 and during the 1950s. Periods of high precipitation occurred
in 1915-1920 and in the 1980s. For OPCNM, there was a slightly increasing trend in monthly
and annual precipitation over the period 1895-1999, a strong drought occurred in the 1950s, and
a lesser drought occurred in the 1970s. No discernable trend in precipitation in southwestern
Arizona or OPCNM was found in the 1990s, which is when the current decline in the U.S.
pronghorn sub-population began.
Since Rowland’s analysis, we had one year characterized by above-average rainfall and abundant
ephemeral forage (2001) followed by a year with virtually no precipitation or ephemeral forage
(2002). Recruitment and survival were high in 2001 and very low in 2002 (Bright and Hervert
2005). Based on the lack of forage and water, and the condition of pronghorn observed, drought is

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considered the proximate cause of the 79% decline in the U.S. pronghorn sub-population from 2000
to 2002. The December 2007 long-term (48-months) drought status report
(http://www.azwater.gov/dwr/drought/documents/December_2007_Drought_Monitor_Report.pdf )
indicates that southwestern Arizona continues to experience abnormally dry to severe drought
conditions. Despite this, since 2002, winter and summer precipitation, in conjunction with
emergency recovery actions, has been adequate to maintain pronghorn reproduction and fawn
survival.
Historically, pronghorn populations must have weathered many severe droughts in the Sonoran
Desert, including many that were more severe and longer term than what has occurred recently.
Given that pronghorn populations survived the droughts of the 1890s, 1950s, 1970s, and others
before those, it is unreasonable to solely attribute recent declines in the U.S. pronghorn
population to drought. OPCNM (2001) concluded, “If (individual) recent dry years have had an
impact on Sonoran pronghorn, it is most likely because in recent decades Sonoran pronghorn
have much more limited options for coping with even brief moderate drought. Because of
restrictions on their movements and range, and increasing human presence within their range,
pronghorn are less able to employ their nomadic strategy in search of relief. It is not that drought
itself is an impact, but possibly that drought has become an impact, due to other factors
confounding the species’ normal ecological strategy.”
Emergency Recovery Actions
A number of critically important emergency recovery projects have been recently initiated in an
attempt to reverse the decline of the U.S. sub-population of the Sonoran pronghorn (Krausman et
al. 2005b). These projects are designed to increase availability of green forage and water during
dry periods and seasons to offset to some extent the effects of drought and barriers that prevent
pronghorn from accessing greenbelts and water, such as the Gila River and Río Sonoyta. Nine
emergency water sources (six on CPNWR, one on OPCNM, and two on BMGR-West) have
been constructed in recent years throughout the range of the U.S. sub-population. Four forage
enhancement plots, each consisting of a well, pump, pipelines and irrigation lines, have been
developed to irrigate the desert and produce forage for pronghorn. One plot is currently being
constructed and two additional plots will be installed over the next five years.
A semi-captive breeding facility at CPNWR was first stocked with pronghorn in 2004 and now
contains 37 animals. As described above, this facility will be used to augment the current U.S.
sub-population, and potentially to establish a second herd at Kofa NWR. These crucial projects,
which we hope will pull the U.S. population back from the brink of extinction, have been
cooperative efforts among FWS, Arizona Game and Fish Department, MCAS-Yuma, Luke Air
Force Base, and OPCNM, with volunteer efforts from the Arizona Desert Bighorn Sheep
Society, Arizona Antelope Foundation, and the Yuma Rod and Gun Club.
D. Past and Ongoing Non-Federal Actions in the Action Area
The Status of the Species section describes a variety of human activities that have affected the
Sonoran pronghorn since initiation of livestock grazing over 300 years ago (Officer 1993). Most

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non-Federal activities that have affected the pronghorn are historical in nature, and pronghorn
have been all but extirpated from private, state, and Tribal lands.
E. Past and Ongoing Federal Actions in the Action Area
Because of the extent of Federal lands in the action area, most activities that currently, or have
recently, affected the U.S. sub-population or their habitat are Federal actions. The primary
Federal agencies involved in activities in the action area include the MCAS-Yuma, Luke Air
Force Base, FWS, BLM, OPCNM, and Border Patrol. In the following discussion, we have
categorized Federal actions affecting the pronghorn as: 1) those actions that have not yet
undergone section 7 consultation (although in some cases consultation has been completed on
components of the Federal activity), and 2) Federal actions that have undergone consultation.
Federal Actions For Which Consultation Has Not Been Completed
1) Tucson Sector of the Border Patrol
We have been in informal consultation with the Tucson Sector Border Patrol regarding
development of a biological assessment for several years (consultation number 02-21-99-I0138). This consultation will encompass all field activities conducted by the Tucson Sector
under their program to detect, deter, and apprehend undocumented immigrants and drug
traffickers. Activities within the Ajo Station of the Tucson Sector have the greatest potential to
adversely affect pronghorn; although currently that Station is being operated out of the Yuma
Sector. Adverse effects may result from patrol and drag road activities, off-road operations,
aircraft overflights, the use and maintenance of sensors, construction of vehicle barriers and
fences, and installation, operation, and maintenance of cameras and communication towers.
From 2002 to 2006, about 180 miles of illegal roads were created in wilderness areas of CPNWR
(Segee and Neeley 2006). These routes were likely created both by Border Patrol and smugglers,
and all are probably used by Border Patrol. Furthermore, the potential for disturbance to
pronghorn due to human presence may increase in areas where agents live on site (i.e., Operation
Grip). Border Patrol activities can be beneficial as well, in that they deter illegal border
crossings, foot traffic, and off-road vehicles in pronghorn habitat associated with undocumented
aliens and smuggling. At the same time, effectiveness of Border Patrol operations elsewhere
along the U.S/Mexico border have driven illegal activities into remote areas, such as CPNWR.
McCasland (pers. comm. 2007) has anecdotal observations suggesting a negative correlation
between areas of high Border Patrol and smuggling traffic and pronghorn use.
2) Smuggler/Drug Interdiction
We are aware of U.S. Customs, Drug Enforcement Authority, and Arizona Army National Guard
smuggler or drug interdiction activities in pronghorn habitat, including vehicle and helicopter
activities. However, none of these agencies have provided information to us about the extent or
types of activities they conduct, and no consultation has occurred on these activities. Impacts are
probably similar in scope to those described for the Tucson Sector activities.
3) BLM Off-Road Vehicle Use Area

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We are aware of an off-road vehicle (ORV) use area located north of Ajo on BLM land, near the
CPNWR, and adjacent to suitable pronghorn habitat. The BLM has not authorized the use of this
ORV area but plans to in the updated Resource Management Plan (RMP) they are developing for
BLM lands in the vicinity. They will request formal section 7 consultation on the updated RMP.
To date, BLM has not provided us with information about the extent and type of use of the ORV
area or its possible effects to pronghorn.
Federal Actions Addressed in Section 7 Consultations
As part of our comprehensive discussion of all past and present actions affecting pronghorn
within the action area, we describe below all biological opinions issued to date on actions that
may affect the pronghorn.
Several opinions addressed projects with minor effects to the pronghorn (capture and collaring of
pronghorn for research purposes, consultation numbers 02-21-83-F-0026 and 02-21-88-F-0006;
installation of a water source in the Mohawk Valley for pronghorn, consultation number 02-2188-F-0081; implementation of the CPNWR Comprehensive Conservation Plan, consultation
number 22410-2006-F-0416; a change in aircraft type from the F-15A/B to the F-15E on
BMGR-East [F-15E Beddown Project], consultation number 02-21-89-F-0008; and the following
projects at OPCNM: widen North Puerto Blanco Road project, consultation number 02-21-01-F0109; roadway and drainage improvements to SR 85, consultation 02-21-01-F-0546; vehicle
barrier, consultation number 02-21-02-F-237; and improvement, maintenance, and use of the
West Boundary Route, consultation number 02-21-05-M-0100 (this opinion has not yet been
finalized)). Incidental take was anticipated only for the Beddown Project in the form of
harassment as a result of aircraft overflights. This project was later incorporated into the
biological opinion on Luke Air Force Base’s activities on the BMGR, discussed below. All of
these formal consultations can be viewed on our website at
http://www.fws.gov/arizonaes/Biological.htm.
Nine biological opinions evaluated major projects with greater effects to pronghorn:
Border Patrol Activities in the Yuma Sector, Wellton Station, Yuma, Arizona
This biological opinion (consultation number 02-21-96-F-0334), issued September 5, 2000,
addressed all Border Patrol activities along the United States/Mexico border in Yuma County
from the Colorado River to about the area of Pinta Sands at the southern end of the Sierra Pinta
Mountains. The Yuma Sector requested reinitiation of consultation, and we delivered a draft
biological opinion in 2004; however, we have not received comments from the Border Patrol to
date. Currently, Border Patrol activities within the Yuma Sector/Wellton Station include
helicopter and ground patrols; drag road preparation and assessment of road maintenance; remote
sensor installation and maintenance; maintenance of pedestrian fences east and north of San
Luis, construction of a vehicle barrier on the CPNWR, apprehensions and rescues; and assistance
to other sectors and agencies. Disturbance to pronghorn was anticipated as a result of on-theground Border Patrol operations, and direct injury or mortality of pronghorn as a result of
collision with Border Patrol vehicles or by low-level helicopter flights abruptly approaching and
startling pronghorn, which may result in injury or energetic stress, particularly during drought.

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Pronghorn may also be adversely affected by noise and visual impacts of helicopter overflights.
To reduce adverse effects on pronghorn, the Border Patrol agreed to implement a number of
conservation measures. We determined that the proposed action was not likely to jeopardize the
continued existence of the pronghorn. We anticipated take in the form of harassment that is
likely to injure up to one pronghorn in 10 years. The following reasonable and prudent measures
were provided: 1) minimize injury of pronghorn; 2) monitor and study reactions of pronghorn
on BMGR to Border Patrol activities; and 3) provide a means to determine the level of incidental
take that results from Border Patrol activities. Several conservation recommendations were also
provided. We are not aware of any incidental take attributable to Yuma Sector activities.
BLM’s Lower Gila South Management Area
Three biological opinions address BLM’s Lower Gila South Management Area. The Lower Gila
South Resource Management Plan-Goldwater Amendment (consultation number 02-21-90-F0042), proposed specific and general management guidance for non-military activities on the
BMGR. The non-jeopardy biological opinion, issued April 25, 1990, was programmatic,
requiring BLM to consult when site-specific projects are proposed. No incidental take was
anticipated. The Lower Gila South Habitat Management Plan (HMP) (consultation number 0221-89-F-0213) provided management guidance for both specific and general actions in
southwestern Arizona. Four actions were addressed in the HMP, including an exchange of 640
acres near Ajo, rehabilitation work on two catchments, and assessment of livestock removal from
pronghorn habitat. Exchange of land out of public ownership may facilitate development or
other uses that would preclude use by pronghorn. The non-jeopardy opinion was issued on May
15, 1990. The biological opinion for the Lower Gila South Resource Management Plan and
Amendment (consultation number 02-21-85-F-0069) addressed programmatic management of
lands in southwestern Arizona, including livestock grazing, wilderness, cultural resources, fire,
minerals and energy, recreation, wildlife management, wood cutting, Areas of Critical
Environmental Concern, and other land uses. The non-jeopardy biological opinion was issued
on March 27, 1998; no incidental take was anticipated. In regard to management on the BMGR,
these three opinions have been replaced by the opinion on the BMGR’s Integrated Natural
Resources Management Plan (INRMP) (see below). The Air Force and MCAS-Yuma have
assumed BLM’s management responsibilities on the BMGR.
BLM grazing allotments in the vicinity of Ajo, Arizona
The original biological opinion (consultation number 02-21-94-F-0192), issued December 3,
1997, addressed effects to pronghorn resulting from issuance of grazing permits on five
allotments, four of which were located near Ajo and Why (Cameron, Childs, Coyote Flat, and
Why allotments); and the fifth near Sentinel (Sentinel allotment). All but portions of allotments
east of Highway 85 were considered to be within the current distribution of the Sonoran
pronghorn. Reinitiations resulted in revised biological opinions dated November 16, 2001,
September 30, 2002, June 21, 2004, March 3, 2005, and March 8, 2007. Under the current
proposed action, the Cameron Allotment is closed, the Sentinel Allotment has been in non-use
for several years, the Coyote Flat and Why allotments were combined into one (Coyote Flat
Allotment), and the Childs Allotment remains relatively unchanged in terms of management.
Effects of livestock grazing activities included reduced forage availability for pronghorn, human

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disturbance due to livestock management, barriers to movement caused by pasture and allotment
fences, and potential for disease transfer from cattle to pronghorn. The March 8, 2007 opinion
concluded that the proposed action was not likely to jeopardize the continued existence of the
pronghorn. No incidental take was anticipated, and none is known to have occurred.
Organ Pipe Cactus National Monument General Management Plan
The original biological opinion (consultation number 02-21-89-F-0078), issued June 26, 1997,
addressed implementation of OPCNM’s General Management Plan (GMP). This opinion was
reinitiated five times, resulting in revised biological opinions dated November 16, 2001, April 7,
2003, March 10 and August 23, 2005, and March 8, 2007. GMP plan elements included: 1)
continuing travel and commerce on SR 85 while enhancing resource protection, 2) seeking
designation of OPCNM as the Sonoran Desert National Park, 3) establishment of partnerships, 4)
increased wilderness and an interagency wilderness and backcountry management plan, 5)
changes in trails, facilities, and primitive camping, and 6) implementation of a Cultural
Resources Management Plan. Included were a number of conservation measures to minimize
impacts to pronghorn. Effects of the action included human disturbance to pronghorn and
habitat due to recreation and management activities. We determined that the proposed action
was not likely to jeopardize the continued existence of the pronghorn. In the latest versions of
the opinion, no incidental take of pronghorn was anticipated. No incidental take is known to
have occurred.
Marine Corps Air Station-Yuma in the Arizona Portion of the Yuma Training Range Complex
The original biological opinion (consultation number 02-21-95-F-0114), was issued on April 17,
1996. That opinion was reinitiated and revised opinions were issued November 16, 2001 and
August 6, 2003. These opinions addressed all proposed and authorized actions on the BMGR by
MCAS-Yuma, including ongoing and proposed changes to military flights over CPNWR and the
BMGR, operation of various training facilities such as landing strips, a rifle range, targets, a
parachute drop zone, a transmitter/telemetry system, ground support areas, and Weapons Tactics
Instructor courses, conducted twice a year (March-April and October-November) that involve
overflights, ground-based activities, and deliverance of ordnance at targets in BMGR-East.
Ground-based activities, such as those of troops and vehicles at ground-support areas were
determined to adversely affect pronghorn habitat use. In areas where helicopters fly particularly
low and create noise and visual stimuli, disturbance of pronghorn was anticipated. Ordnance
delivery at North and South TACs could disturb pronghorn, and ordnance, live fire, and shrapnel
could potentially strike and kill or injure a pronghorn. MCAS-Yuma proposed measures to
reduce the direct and indirect impacts of the proposed action, including measures to reduce or
eliminate take of Sonoran pronghorn and to minimize destruction and degradation of habitat.
We determined that the proposed action was not likely to jeopardize the continued existence of
the pronghorn. In the 2003 version of the BO, no incidental take of pronghorn was anticipated
and none is known to have occurred.
Luke Air Force Base Use of Ground-Surface and Airspace for Military Training on the BMGR

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The original biological opinion (consultation number 02-21-96-F-0094), issued August 27, 1997,
addressed military use of the airspace above and the ground space on BMGR-East and CPNWR
by Luke Air Force Base. Military activities within the area of overlap with the CPNWR were
limited to use of airspace and operation of four Air Combat Maneuvering Instrumentation sites.
Military activities occurring within BMGR-East included: airspace use, four manned air-toground ranges, three tactical air-to-ground target areas, four auxiliary airfields, Stoval Airfield,
and explosive ordnance disposal/burn areas. Primary potential effects of the action included
habitat loss due to ground-based activities, harassment and possible mortality of pronghorn at
target areas, and disturbance of pronghorn due to military overflights. We determined that the
proposed action was not likely to jeopardize the continued existence of the pronghorn. This
opinion was reinitiated in 2001 and 2003, resulting in revised opinions dated November 16, 2001
and August 6, 2003. In the latest (2003) opinion, no incidental take was anticipated. We are not
aware of any take of pronghorn confirmed attributable to Luke Air Force Base use of the groundsurface and airspace on the BMGR. A pronghorn found dead near a target may have been
strafed, but it may also have died from other causes (see “Effects of the Proposed Action” in the
2003 opinion for a full discussion of this incident).
During the development of these opinions, Luke Air Force Base made substantial commitments
to minimize the effects of their activities on the Sonoran pronghorn, and additionally committed
to implementing a variety of recovery projects recommended by the Sonoran Pronghorn
Recovery Team.
Western Army National Guard Aviation Training Site Expansion Project
The non-jeopardy biological opinion for WAATS (consultation number 02-21-92-F-0227) was
issued on September 19, 1997; however, Sonoran pronghorn was not addressed in formal
consultation until reinitiations and revised opinions dated November 16, 2001 and August 6,
2003. The purpose of WAATS is to provide a highly specialized environment to train ARNG
personnel in directed individual aviator qualification training in attack helicopters. The WAATS
expansion project included: 1) expansion of the existing Tactical Flight Training Area, which
includes establishing four Level III touchdown sites, 2) development of the Master Construction
Plan at the Silver Bell Army Heliport, and 3) establishment of a helicopter aerial gunnery range
for use by the ARNG on East TAC of the BMGR. All activities that are part of the proposed
action occur outside the current range of the pronghorn, with the exception of training at North
TAC. Training at North TAC only occurs when East TAC is closed for annual maintenance and
EOD clearances (4-6 weeks each year). Effects to pronghorn at North TAC are minimized by
monitoring protocols established by Luke Air Force Base. Training at East TAC could preclude
recovery of historical habitat if the many other barriers that prevent pronghorn use of East TAC
were removed. The November 16, 2001 and August 6, 2003 opinions found that the proposed
action was not likely to jeopardize the continued existence of the pronghorn. No incidental take
was anticipated and none is known to have occurred as a result of the proposed action. ARNG
included the following conservation measures as part of their proposed action: 1) they proposed
to study the effects of low-level helicopter flights on a surrogate pronghorn population at Camp
Navajo, and 2) they committed to funding up to five percent of emergency recovery actions on
the BMGR.

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BMGR Integrated Natural Resources Management Plan
The non-jeopardy opinion for this action was issued on August 26, 2005. The Military Lands
Withdrawal Act (MLWA) of 1999 required that the Secretaries of the Air Force, Navy, and
Interior jointly prepare an INRMP for the BMGR, the purpose of which was to provide for the
“proper management and protection of the natural and cultural resources of [the range], and for
sustainable use by the public of such resources to the extent consistent with the military purposes
[of the BMGR].” The proposed action was comprehensive land management, including public
use restrictions, authorizations, and permitting on portions of the BMGR regarding camping,
vehicle use, shooting, entry into mines, firewood collection and use, rockhounding, and other
activities; natural resources monitoring, surveys, and research; habitat restoration; wildlife water
developments; development of a wildfire management plan; law enforcement; limitations on the
locations of future utility projects and the Yuma Area Service Highway; control of trespass
livestock; and designation of special natural/interest areas, while allowing other designations to
expire. The proposed action included many land use prescriptions that would improve the
baseline for the pronghorn. No incidental take was anticipated, and none is known to have
occurred from the proposed action.
Department of Homeland Security Permanent Vehicle Barrier
This biological opinion (consultation number 22410-2006-F-0113), issued September 15, 2006,
addressed the CBP - Office of the Border Patrol’s installation of a permanent vehicle barrier (as
well as access improvements, construction/improvement of border roads, and associated
maintenance and patrol activities) along the border from the western end of the OPCNM barrier
to Avenue C just east of San Luis, Arizona. Effects to pronghorn included 1) disturbance of a
narrow swath of habitat along the border, 2) presence of construction crews and vehicles that
may disturb or preclude use of the area by pronghorn, 3) presence of maintenance and patrol
vehicles and crews along the barrier access road, and 4) dramatic reduction or elimination of
illegal drive-throughs and required law enforcement response, with much reduced route
proliferation and habitat damage from off-highway vehicles. We determined that the proposed
action was not likely to jeopardize the continued existence of the pronghorn. No incidental take
of pronghorn was anticipated. Subsequent to issuing the biological opinion, the action was
changed to include the installation of a hybrid-style fence designed to prevent the passage of
pedestrians. Because all environmental laws were waived (as permitted by the Real ID Act of
2005) by Secretary of the DHS, CBP never reinitiated consultation with us regarding this change
to their proposed action.
F. Summary of Activities Affecting Sonoran Pronghorn in the Action Area
Historically, livestock grazing, hunting or poaching, and development along the Gila River and
Río Sonoyta were all probably important factors in the well-documented Sonoran pronghorn
range reduction and apparent population decline that occurred early in the 20th century.
Historical accounts and population estimates suggest pronghorn were never abundant in the 20th
century, but recently, the estimated size of the wild population in the action area declined from
179 (1992) to 21 (December 2002) and 68 (2006). At 21 and 68, genetic diversity could erode,
and the sub-population is in imminent danger of extirpation due to human-caused impacts, or

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natural processes, such as predation or continued drought. Although the proximate cause of the
decline during 2002 was drought, human activities limit habitat use options by pronghorn and
increase the effects of drought on the sub-population. The U.S. pronghorn sub-population is
isolated from other sub-populations in Sonora by a highway and the U.S./Mexico boundary
fence, and access to the greenbelts of the Gila River and Río Sonoyta, which likely were
important sources of water and forage during drought periods, has been severed.
Within its remaining range, the pronghorn is subjected to a variety of human activities that
disturb the pronghorn and its habitat, including military training, increasing recreational
activities, grazing, increasing presence of undocumented immigrants and smugglers, and in
response, increased law enforcement activities. MCAS-Yuma (2001) quantified the extent of the
current pronghorn range that is affected by various activities and found the following: recreation
covers 69.6 percent of the range, military training on North and South TACs covers 9.8 percent,
active air-to-air firing range covers 5.8 percent, proposed EOD five-year clearance areas at North
and South TACs and Manned Range 1 cover 1.0 percent, and MCAS-Yuma proposed ground
support areas and zones cover 0.29 percent. Border Patrol enforcement and smuggling activities
occur throughout the range of the pronghorn, and anecdotal evidence suggests pronghorn are
avoiding areas of high enforcement and illegal activities. Historically, pronghorn tended to
migrate to the southeastern section of their range (southeastern CPNWR and OPCNM) during
drought and in the summer. Within the last few years, very few pronghorn have been observed
south of El Camino del Diablo on CPNWR. This suggests illegal smuggling and the interdiction
of these illegal activities have resulted in pronghorn avoiding areas south of El Camino del
Diablo; these areas are considered important summer habitat for pronghorn and may have longterm management and recovery implications (McCasland pers. comm. 2007). All of the valleys
at CPNWR, which were once nearly pristine wilderness Sonoran Desert, now have many
braided, unauthorized routes through them and significant vehicle use by USBP agents pursuing
illegal immigrants and smugglers. OPCNM (2001) identified 165 human activities in the range
of the pronghorn, of which 112 were adverse, 27 were beneficial, 26 had both adverse and
beneficial effects, and four had unknown effects. OPCNM (2001) concluded that in regard to the
pronghorn, “while many projects have negligible impacts on their own, the sheer number of
these actions is likely to have major adverse impacts in aggregate.”
Although major obstacles to recovery remain, since 2002, numerous crucial recovery actions
have been implemented in the U.S. range of the species, including nine emergency waters and
four forage enhancement plots, with additional waters and forage plots planned. The projects
tend to offset the effects of drought and barriers to prevent movement of pronghorn to greenbelts
such as the Gila River and Río Sonoyta. A semi-captive rearing facility, built on Cabeza Prieta
NWR, currently holds 37 pronghorn. This facility will provide pronghorn to augment the
existing sub-population and hopefully to establish a second U.S. sub-population at Kofa NWR.
The current range of the pronghorn in the U.S. is almost entirely comprised of lands under
Federal jurisdiction; thus authorized activities that currently affect the pronghorn in the action
area are almost all Federal actions. However, illegal, unauthorized foot traffic and off-road
vehicle activity, but also required Federal law enforcement response have been and continue to
be significant threats to the pronghorn and its habitat. Prior to November 2001, in seven of 12
biological opinions issued by FWS that analyzed impacts to the pronghorn, we anticipated that

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take would occur. In total, we anticipated take of five pronghorn in the form of direct mortality
every 10-15 years, and an undetermined amount of take in the form of harassment. Given the
small and declining population of pronghorn in the U.S. at the time the opinions were written,
take at the levels anticipated in the biological opinions would constitute a substantial impact to
the population.
Changes made in proposed actions and reinitiated biological opinions from 2001 to the present,
plus the findings in other recent opinions, reduced the amount or extent of incidental take
anticipated to occur from Federal actions. Significantly, we have been successful working with
action agencies to modify proposed actions and to include significant conservation measures that
reduce adverse effects to the pronghorn and its habitat. The only current opinion that anticipates
incidental take is the Yuma Sector opinion, in which we anticipated take in the form of
harassment that is likely to injure up to one pronghorn in 10 years. With the exception of likely
capture-related deaths during telemetry studies (which were addressed in 10(a)(1)(A) recovery
permits), we are unaware of any confirmed incidental take resulting from the Federal actions
described here (although a pronghorn may have been strafed near one of the targets on BMGREast – see above).
We believe the aggregate effects of limitations or barriers to movement of pronghorn and
continuing stressors, including habitat degradation and disturbance within the pronghorn’s
current range resulting from a myriad of human activities, exacerbated by periodic dry seasons or
years, are responsible for the present precarious status of the Sonoran pronghorn in the action
area. However, collaborative, multi-agency and multi-party efforts to develop forage
enhancement plots and emergency waters, combined with the success of the semi-captive
breeding facility, plus planned future recovery actions, including establishment of a second U.S.
sub-population, provide hope that recovery of the Sonoran pronghorn in the U.S. is achievable.
EFFECTS OF THE ACTION
Effects of the action refer to the direct and indirect effects of an action on the species or critical
habitat, together with the effects of other activities that are interrelated and interdependent with
that action that will be added to the environmental baseline. Interrelated actions are those that
are part of a larger action and depend on the larger action for their justification. Interdependent
actions are those that have no independent utility apart from the action under consideration.
Indirect effects are those that are caused by the proposed action and are later in time, but are still
reasonably certain to occur.
Sonoran Pronghorn
The proposed fence project may result in disturbance to Sonoran pronghorn and/or degradation
of pronghorn habitat. Construction and maintenance of the fence and roads, as well as possible
increased illegal pedestrian and law enforcement activity to the west of the project will result in
removal, destruction, and disturbance of vegetation that may provide forage and cover to
pronghorn and may visually and auditorily disturb pronghorn. Though activities associated with
the proposed project may be detrimental to pronghorn, conservation measures included in the
project description will minimize and help offset disturbance to pronghorn and degradation of

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their habitat. The fence may have a beneficial effect on pronghorn and pronghorn habitat in the
Lukeville area if it is successful in reducing the number of illegal pedestrians that currently cross
into the pronghorn range from Mexico. However, habitat damage and disturbance of pronghorn
to the west of the project may increase if illegal traffic is redirected to the west of the fence.
Effects from Construction and Maintenance Activities
Construction and maintenance activities associated with the project may result in some, though
we anticipate minimal, disturbance to Sonoran pronghorn, particularly on the western slope of
Sonoyta Hill, where there is a greater chance for pronghorn to occur. At least during the project
construction phase, disturbance will be minimized by having a biological monitor present (only
during construction activities on the western slope of Sonoyta Hill) to ensure that all project
construction activities are suspended if Sonoran pronghorn are detected within 0.62 mile of
project activities. Access to the western portion of the construction site (i.e., west of Highway
85) will be along the OPCNM border road and South Puerto Blanco road. Though use of these
roads may result in some disturbance to Sonoran pronghorn, because pronghorn are not likely to
occur near the border or South Puerto Blanco roads between Highway 85 and Sonoyta Hill
(based on pronghorn detections for the last 13 years and abundant near-by human presence), we
anticipate disturbance to pronghorn will be minimal. Vehicles associated with construction and
maintenance could also collide with pronghorn causing injury and/or death. However, we
believe the likelihood of collisions with construction and maintenance vehicles is probably low
because, as described in the “Status of the Species”, pronghorn are relatively rare, particularly
within the project corridor; vehicles will travel at speeds less than 25 miles per hour; and because
we are not aware of any such collisions in the U.S., or along unpaved routes anywhere within the
range of the Sonoran pronghorn.
Effects from Pedestrian Traffic and Patrol Activities
The fence may have a beneficial effect on Sonoran pronghorn if it reduces illegal pedestrian
activities and law enforcement pursuits within the Sonoran pronghorn range. These benefits are
most likely to accrue immediately north of the pedestrian fence in the Lukeville area. However,
if illegal traffic is redirected, particularly to the west of fence, disturbance to pronghorn and
important pronghorn habitat in that area will increase. Patrol activities, which are expected to
increase to the west of the fence if illegal traffic shifts west, may additionally disturb pronghorn
and their habitat. As noted in the Environmental Baseline, pronghorn appear to be avoiding
areas south of the Camino del Diablo in CPNWR possibly due to high levels of smuggling and
required law enforcement response. Shifting traffic to west of the Lukeville fence would
exacerbate these effects. Increased illegal and law enforcement activities in pronghorn habitat
could cause pronghorn to flee and result in short-term denial of access to habitat, both of which
would likely result in severe adverse physiological effects to pronghorn. As discussed in the
“Status of the Species” and below, Sonoran pronghorn are sensitive to human disturbance.
Vehicle traffic is disturbing to pronghorn and will often cause flight or startle responses with
associated adverse physiological changes. Hughes and Smith (1990) found that pronghorn
immediately ran 1,310-1,650 feet from a vehicle. Krausman et al. (2001) found that Sonoran
pronghorn reacted to ground disturbances (vehicles or people on foot) with a change in behavior
37 percent of the time, resulting in the animals running or trotting away 2.6 percent of the time.
Wright and deVos (1986) noted that Sonoran pronghorn exhibit “a heightened response to
human traffic” as compared to other subspecies of pronghorn. Disturbance and flight of

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ungulates are known to result in a variety of physiological effects that are adverse, including
elevated metabolism, lowered body weight, reduced fetus survival, and withdrawal from suitable
habitat (Geist 1971, Harlow et al. 1987), which may be exacerbated in harsh environments such
as those occupied by Sonoran pronghorn. Disturbance may also lead to mortality, including
increased vulnerability to predator attack and susceptibility to heat stress and malnutrition.
Because pronghorn are rare, encounters with illegal immigrants and smugglers should be a
relatively rare event. The likelihood of encounters will increase however if illegal traffic
increases to the west of the fence. Patrol vehicles pursuing illegal immigrants/smugglers along
the improved vehicle route adjacent to the pedestrian fence or in areas to west of the fence in
response a shift in illegal traffic could also collide with pronghorn causing injury and/or death.
However, we believe the likelihood of collisions with patrol vehicles is probably low because
vehicles will not likely be traveling at high speeds (due to traveling primarily along unimproved
routes); we are not aware of any such collisions in the U.S., or along unpaved routes anywhere
within the range of the Sonoran pronghorn; and pronghorn are relatively rare. Shifts in illegal
and law enforcement activity to the west could also further degrade pronghorn habitat in that
area. Trails and other soil disturbance can increase erosion, promote the spread of invasive
species, and increase the potential for fires, which can adversely affect Sonoran pronghorn
habitat. Additionally, off-road vehicle travel can cause changes in surface hydrology (from
channelization of water in entrenched vehicle track prisms), which may substantially impact
vegetation that provides forage and cover to pronghorn.
However, if patrol increases to the west of the fence along the border, and illegal activity is more
successfully interdicted at the border, we anticipate the frequency of law enforcement pursuits
through the action area should decrease, which will minimize disturbance to pronghorn and
degradation of their habitat. Increased patrol along the border may disturb pronghorn and cause
them to avoid or less frequently use the border area. However, because pronghorn are rare along
the border, encounters with patrol activities near the border should be a relatively rare event.
Habitat Loss and Degradation
The proposed project would result in the direct disturbance of approximately 45 acres (this
includes 17 acres of previously disturbed area); however, much of this is not considered suitable
habitat for pronghorn due to abundant near-by human presence or rocky, steep terrain. However,
the 45 acres of disturbed ground will be susceptible to colonization by invasive non-native plants
such as buffelgrass, Sahara mustard, and Eruca vesicaria. Non-native species may outcompete
natives and carry fire which could impact near-by pronghorn habitat. As stated in the “Status of
the Species”, most Sonoran Desert trees, shrubs, and cacti, which provide thermal cover and
forage for pronghorn, are very fire intolerant.
Removal of vegetation via fire and direct disturbance in the pronghorn’s range decreases the
amount of thermal cover and forage available to pronghorn, with adverse effects to pronghorn,
especially in drought situations when less forage is already available. The amount of habitat loss
due to fence and road construction, however, is extremely small in the context of the
approximately 2 million acres of potentially suitable habitat available to the U.S. sub-population
of Sonoran pronghorn. The amount of habitat loss due to potential fire cannot be predicted;
however, fire could impact a significant amount of pronghorn habitat. Control of non-native

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plants within the project footprint, as proposed by CBP, should help decrease the risk of fire
within the Sonoran pronghorn range. Additionally, restoration of 84 acres, if it occurs within the
Sonoran pronghorn range, should help offset impacts to pronghorn habitat caused by the project.
Barriers to Pronghorn Movement
The proposed project overlays an existing barrier to Sonoran pronghorn movement, the
international boundary. It is generally thought that pronghorn currently do not cross the
international boundary due to the combined barrier effects of: (1) the international-boundary
livestock fence; (2) Mexican Highway 2; (3) right-of-way fencing and livestock fencing that is
intermittent along Highway 2 between Sonoyta and San Luis; and (4) human settlements and
activity concentrations, which are expanding linearly along the boundary. Mexican Highway 2
does not continue near the border east of Lukeville (it turns south) and thus does not act as a
barrier to trans-border Sonoran pronghorn movement along the eastern portion of the proposed
project. Sonoran pronghorn, however, in recent years have only rarely been documented using
the eastern portion of the proposed project area, likely due to the barrier effect of Highway 85.
The proposed fence would completely impede any attempted trans-border Sonoran pronghorn
movements near Lukeville. However, because Sonoran pronghorn are not known to cross the
international border due to aforementioned existing barriers, we do not anticipate the fence will
affect their trans-border movement patterns.
Conservation Measures
CBP’s commitments to provide funding to fill a Sonoran pronghorn water for 10 years (at an
annual cost of $2,500.00) will help offset potential impacts to pronghorn that may occur as a
result of this project and will generally aid in the conservation and recovery of pronghorn.
Furthermore, restoration of 84 acres, if it occurs with the Sonoran pronghorn range, will also
help offset project impacts to pronghorn.
Pronghorn Status
The most recent formal Sonoran pronghorn survey in December 2006 resulted in an estimated 68
wild pronghorn in the U.S. population, which was a substantial increase from an estimated 18
wild pronghorn in the U.S in 2002. This increase can likely be attributed to improved habitat
conditions since 2002 when a severe drought occurred, as well as emergency recovery actions
such as forage enhancement plots and waters (see details under the “Environmental Baseline”),
which undoubtedly offset to some extent the effects of drought and barriers that prevent
pronghorn from accessing greenbelts and water, such as the Gila River and Río Sonoyta. We
expect these recovery actions may also help offset adverse effects from this project as well as
other activities within the action area that disturb pronghorn and their habitat. Because
pronghorn remain critically endangered, however, it is imperative that all adverse effects to
pronghorn from the proposed action and other activities are minimized and offset to the greatest
extent possible.
CUMULATIVE EFFECTS
Cumulative effects include the effects of future State, tribal, local or private actions that are
reasonably certain to occur in the action area considered in this biological opinion. Future

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Federal actions that are unrelated to the proposed action are not considered in this section
because they require separate consultation pursuant to section 7 of the Act.
Most lands within the action area (current range of the pronghorn within Arizona) are managed
by Federal agencies; thus, most activities that could potentially affect pronghorn are Federal
activities that are subject to section 7 consultation. The effects of these Federal activities are not
considered cumulative effects. Relatively small parcels of private and State lands occur within
the currently-occupied range of the pronghorn near Ajo and Why, north of the BMGR from
Dateland to Highway 85, and from the Mohawk Mountains to Tacna. State inholdings in the
BMGR were acquired by the USAF. Continuing rural and agricultural development, recreation,
vehicle use, grazing, and other activities on private and State lands adversely affect pronghorn
and their habitat. MCAS-Yuma (2001) reports that 2,884 acres have been converted to
agriculture near Sentinel and Tacna. These activities on State and private lands and the effects of
these activities are expected to continue into the foreseeable future. Historical habitat and
potential recovery areas currently outside of the current range are also expected to be affected by
these same activities on lands in and near the action area in the vicinity of Ajo, Why, and Yuma.
Of particular concern are illegal border crossings by undocumented immigrants and smugglers.
In fiscal year 2005, the Yuma Sector of the Office of Border Patrol (OBP) apprehended record
numbers of illegal immigrants and smugglers, and from October 1, 2005 to May 2006, 96,000
were made, which was a 13% increase over the same time period in 2005 (Gerstenzang 2006).
In 2001, estimates of undocumented migrant traffic reached 1,000 per night in OPCNM alone
(National Park Service 2001 or OPCNM 2001) and an estimated 150,000 people entered the
OPCNM illegally from Mexico (Milstead and Barns 2002). Increased presence of the Border
Patrol in the Douglas, Arizona area, and in San Diego (Operation Gatekeeper) and southeastern
California, pushed illegal immigrant and smuggler traffic into remote desert areas, such as
CPNWR, OPCNM, and BMGR (Klein 2000). Though the operation of Camp Grip within the
CPNWR and the temporary camp detail at Bates Well on the OPCNM reduced the number of
illegal drive-throughs in the eastern portion of the CPNWR in FY 2005 (Hubbard 2005, as cited
in U.S. Customs and Border Protection 2005). In recent years, the number of illegal roads and
foot trails created by illegal immigrants within the CPNWR has increased substantially (U.S.
Customs and Border Protection 2005, C. McCasland pers. comm. 2007). These illegal crossings
and required law enforcement response have resulted in route proliferation, off-highway vehicle
activity, increased human presence in backcountry areas, discarded trash, abandoned vehicles,
cutting of firewood, illegal campfires, and increased chance of wildfire. Habitat degradation and
disturbance of pronghorn almost certainly result from these illegal activities. Currently, much of
the illegal traffic travels through the southern passes of the Growler Mountains and lead either
through or by all of our forage enhancements and captive rearing pen in the Child's Valley, with
potential to impact these recovery projects and use of the area by pronghorn (C. McCasland pers.
comm. 2007). Probably due to increased enforcement presence, ongoing construction of a
vehicle barrier at CPNWR, and the vehicle barrier at OPCNM, all forms of illegal activities
except narcotics trafficking are significantly down so far in fiscal year 2008 as compared to the
same period in fiscal year 2007. Apprehensions are down from 40-67% at OPCNM and
CPNWR over this period, and thus far in FY 08 no drive-throughs have occurred at OPCNM
(CBP presentation to the Borderlands Management Task Force, January 16, 2008). Despite high
levels of illegal activity and required law enforcement response throughout the action area,

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pronghorn in the U.S. have managed to increase since 2002, although their use of areas subject to
high levels of illegal use and law enforcement have likely declined, as discussed above.
We expect illegal activities and their effects on pronghorn to continue, though they should be
reduced once the PVB on CPNWR is completed (as of this writing, the PVB has been installed
from the border of OPCNM and CPNWR to the boundary of Pima and Yuma counties).
CONCLUSION
After reviewing the current status of the Sonoran pronghorn, the environmental baseline for the
action area, the effects of the proposed activities associated with the Lukeville fence project, and
the cumulative effects, it is our biological opinion the proposed action is not likely to jeopardize
the continued existence of the Sonoran pronghorn. No critical habitat has been designated for
this species, therefore, none will be affected. Our conclusion is based on the following:
1. The Sonoran pronghorn population has increased since 2002, despite high levels of
human use in the form of off- and on-road vehicle and foot travel by smugglers, illegal
immigrants, and law enforcement.
2. Completion of forage enhancement plots, waters, and the semi-captive breeding facility
have helped make the pronghorn population in the U.S. more secure and more resistant to
drought and other stressors.
3. Loss of pronghorn habitat resulting from this project is very small in the context of the
approximately 2 million acres of potentially suitable habitat available to the U.S. subpopulation of Sonoran pronghorn. Additionally, habitat disturbance will be minimized
by conducting project activities within previously disturbed areas to the extent
practicable.
4. The likelihood of pronghorn crossing the international boundary with Mexico in the
project area is currently very low because of current physical barriers (e.g., Mexico
Highway 2) and human activities. Therefore, the presence of the Lukeville fence is
unlikely to result in additional barriers to pronghorn movement across the international
boundary.
5. Conservation measures included in the proposed action will reduce disturbance to
pronghorn during project construction activities (i.e., the presence of a biological monitor
to ensure that all project construction activities are suspended if pronghorn are detected
within 0.62 mile of project activities).
6. Conservation measures included in the proposed action (i.e., funding to fill a pronghorn
water and habitat restoration) will help offset adverse effects to pronghorn that could
result from implementation of the project.
7. When added to the environmental baseline, the status of the species, and cumulative
effects, the effects of the proposed action do not reduce appreciably the likelihood of

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survival and recovery of the subspecies in the wild. Therefore, the proposed action will
not jeopardize the continued existence of the subspecies. Though illegal activity could
increase to the west of the fence, such activity should be reduced by CPB/USBP’s
assignment of additional agents to unprotected areas. The presence of a vehicle barrier to
the west of the fence also halts most or all illegal vehicle traffic. Consequently, adverse
effects to pronghorn from possible increased illegal activity should be minimized.
Additionally, once the Lukeville fence is completed we expect to see a dramatic decrease
in illegal traffic in the Lukeville area. Decreased illegal and legal human activity within
pronghorn habitat in the vicinity of Lukeville will be beneficial to pronghorn.
The conclusions of this biological opinion are based on full implementation of the project as
described in the “Description of the Proposed Action” section of this document, including any
conservation measures that were incorporated into the project design.
INCIDENTAL TAKE STATEMENT
Section 9 of the ESA and Federal regulation pursuant to section 4(d) of the ESA prohibit the take
of endangered and threatened species, respectively, without special exemption. “Take” is defined
as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or to attempt to
engage in any such conduct. “Harm” is defined to include significant habitat modification or
degradation that results in death or injury to listed species by significantly impairing essential
behavioral patterns, including breeding, feeding, or sheltering (50 CFR 17.3). “Harass” is
defined as intentional or negligent actions that create the likelihood of injury to listed species to
such an extent as to significantly disrupt normal behavior patterns which include, but are not
limited to, breeding, feeding or sheltering (50 CFR 17.3). “Incidental take” is defined as take
that is incidental to, and not the purpose of, the carrying out of an otherwise lawful activity.
Under the terms of section 7(b)(4) and section 7(o)(2), taking that is incidental to and not
intended as part of the agency action is not considered to be prohibited taking under the ESA
provided that such taking is in compliance with the terms and conditions of this incidental take
statement.
AMOUNT OR EXTENT OF TAKE ANTICIPATED
We do not anticipate the proposed action will result in incidental take of Sonoran pronghorn for
the following reasons:
1. Pronghorn are rare; making encounters with human activities (both legal and illegal)
associated with the Lukeville fence project a relatively rare event.
2. Measures included in the proposed action, such as the daily surveys for Sonoran
pronghorn, will further reduce the potential for take.
3. No incidental take of Sonoran pronghorn is known to have occurred in Arizona due to
CBP/OBP or illegal immigrant/smuggler activities.
LESSER LONG-NOSED BAT

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STATUS OF THE SPECIES
A. Species Description
The lesser long-nosed bat is a medium-sized, leaf-nosed bat. It has a long muzzle and a long
tongue, and is capable of hover flight. These features are adaptations for feeding on nectar from
the flowers of columnar cacti (e.g., saguaro; cardon, Pachycereus pringlei; and organ pipe
cactus, Stenocereus thurberi) and from paniculate agaves (e.g., Palmer's agave, Agave palmeri)
(Hoffmeister 1986). The lesser long-nosed bat was listed (originally, as Leptonycteris sanborni;
Sanborn's long-nosed bat) as endangered in 1988 (U.S. Fish and Wildlife Service 1988). No
critical habitat has been designated for this species. A recovery plan was completed in 1994
(U.S. Fish and Wildlife Service 1997). Loss of roost and foraging habitat, as well as direct
taking of individual bats during animal control programs, particularly in Mexico, have
contributed to the current endangered status of the species. Recovery actions include roost
monitoring, protection of roosts and foraging resources, and reducing existing and new threats.
B. Distribution and Life History
The lesser long-nosed bat is migratory and found throughout its historical range, from southern
Arizona and extreme southwestern New Mexico, through western Mexico, and south to El
Salvador. It has been recorded in southern Arizona from the Picacho Mountains (Pinal County)
southwest to the Agua Dulce Mountains (Pima County) and Copper Mountains (Yuma County),
southeast to the Peloncillo Mountains (Cochise County), and south to the international boundary.
Roosts in Arizona are occupied from late April to September (Cockrum and Petryszyn 1991) and
on occasion, as late as November (Sidner 2000); the lesser long-nosed bat has only rarely been
recorded outside of this time period in Arizona (U. S. Fish and Wildlife Service 1997,
Hoffmeister 1986, Sidner and Houser 1990). In spring, adult females, most of which are
pregnant, arrive in Arizona gathering into maternity colonies. These roosts are typically at low
elevations near concentrations of flowering columnar cacti. After the young are weaned these
colonies mostly disband in July and August; some females and young move to higher elevations,
primarily in the southeastern parts of Arizona near concentrations of blooming paniculate
agaves. Adult males typically occupy separate roosts forming bachelor colonies. Males are
known mostly from the Chiricahua Mountains and recently the Galiuro Mountains (personal
communication with Tim Snow, Arizona Game and Fish Department, 1999) but also occur with
adult females and young of the year at maternity sites (U. S. Fish and Wildlife Service 1997).
Throughout the night between foraging bouts, both sexes will rest in temporary night roosts
(Hoffmeister 1986).
Lesser long-nosed bats appear to be opportunistic foragers and extremely efficient fliers. They
are known to fly long distances from roost sites to foraging sites. Night flights from maternity
colonies to flowering columnar cacti have been documented in Arizona at 15 miles, and in
Mexico at 25 miles and 36 miles (one way) (Dalton et al. 1994; personal communication with V.
Dalton, 1997; personal communication with Y. Petryszyn, University of Arizona, 1997). Steidl
(personal communication, 2001) found that typical one-way foraging distance for bats in
southeastern Arizona is roughly 12.5 miles. A substantial portion of the lesser long-nosed bats
at the Pinacate Cave in northwestern Sonora (a maternity colony) fly 25-31 miles each night to

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foraging areas in OPCNM (U.S. Fish and Wildlife Service 1997). Horner et al. (1990) found
that lesser long-nosed bats commuted 30-36 miles round trip between an island maternity roost
and the mainland in Sonora; the authors suggested these bats regularly flew at least 47 miles each
night. Lesser long-nosed bats have been observed feeding at hummingbird feeders many miles
from the closest known potential roost site (personal communication with Yar Petryszyn,
University of Arizona, 1997).
Lesser long-nosed bats, which often forage in flocks, consume nectar and pollen of paniculate
agave flowers and the nectar, pollen, and fruit produced by a variety of columnar cacti. Nectar
of these cacti and agaves is high energy food. Concentrations of some food resources appear to
be patchily distributed on the landscape, and the nectar of each plant species used is only
seasonally available. Cacti flowers and fruit are available during the spring and early summer;
blooming agaves are available primarily from July through October. In Arizona, columnar cacti
occur in lower elevational areas of the Sonoran Desert region, and paniculate agaves are found
primarily in higher elevation desert scrub areas, semi-desert grasslands and shrublands, and into
the oak woodland (Gentry 1982). Lesser long-nosed bats are important pollinators for agave and
cacti, and are important seed dispersers for some cacti.
C. Status and Threats
Recent information indicates that lesser long-nosed bat populations appear to be increasing or
stable at most Arizona roost sites identified in the recovery plan (AGFD 2005, Tibbitts 2005,
Wolf and Dalton 2005). Lesser long-nosed bat populations additionally appear to be increasing
or stable at other roost sites in Arizona and Mexico not included for monitoring in the recovery
plan (Sidner 2005). Less is known about lesser long-nosed bat numbers and roosts in New
Mexico. Though lesser long-nosed bat populations appear to be doing well, many threats to their
stability and recovery still exist, including excess harvesting of agaves in Mexico; collection and
destruction of cacti in the U.S.; conversion of habitat for agricultural and livestock uses,
including the introduction of bufflegrass, a non-native, invasive grass species; wood-cutting;
drought; fires; human disturbance at roost sites; and urban development.
Approximately 20 – 25 large lesser long-nosed bat roost sites, including maternity and latesummer roosts, have been documented in Arizona (personal communication with Scott
Richardson, FWS, 2006). Of these, 10 – 20 are monitored on an annual basis depending on
available resources. Monitoring in Arizona in 2004 documented approximately 78,600 lesser
long-nosed bats in late-summer roosts and approximately 34,600 in maternity roosts. Ten to 20
lesser long-nosed bat roost sites in Mexico are also monitored annually. Over 100,000 lesser
long-nosed bats are found at just one natural cave at the Pinacate Biosphere Reserve, Sonora,
Mexico (Cockrum and Petryszyn 1991). The numbers above indicate that although a relatively
large number of lesser long-nosed bats exist, the relative number of known large roosts is quite
small.
Maternity roosts, suitable day roosts, and concentrations of food plants are all critical resources
for the lesser long-nosed bat. All of the factors that make roost sites useable have not yet been
identified, but maternity roosts tend to be very warm and poorly ventilated (U.S. Fish and
Wildlife Service 1997). Human presence/disturbance at roosts is clearly an important factor as

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bats appear to be particularly sensitive to human disturbance at roost sites. For example, the
illegal activity, presumably by immigrants or smugglers, at the Bluebird maternity roost site,
caused bats to abandon the site in 2002, 2003, and 2005. The presence of alternate roost sites
may be critical when this type of disturbance occurs.
The lesser long-nosed bat recovery plan (U.S. Fish and Wildlife Service 1997) identifies the need
to protect foraging areas and food plants such as columnar cacti and agaves. More information
regarding the average size of foraging areas around roosts would be helpful to identify the
minimum area around roosts that should be protected to maintain adequate forage resources.
The 2005 fires referred to under Sonoran Pronghorn “Status of the Species” affected some lesser
long-nosed bat foraging habitat, though the extent is unknown. For example, the Goldwater,
Aux, and Sand Tank Fire Complexes on BMGR-East burned through and around isolated
patches of saguaros, but the immediate effects and longer term impacts of the fires on saguaros
are not yet known. Monitoring of saguaro mortality rates should be done to assess the impacts
on potential lesser long-nosed bat foraging habitat. Fire suppression activities associated with
the 2005 fires could also have affected foraging habitat. For example, slurry drops may have left
residue on saguaro flowers, which could have impacted lesser long-nosed bat feeding efficiency
or resulted in minor contamination.
Drought (see the “Status of the Species” and “Environmental Baseline” for Sonoran pronghorn
for further details regarding drought) may affect lesser long-nosed bat foraging habitat, though
the effects of drought on bats are not well understood. The drought in 2004 resulted in near
complete flower failure in saguaros throughout the range of lesser long-nosed bats. During that
time however, in lieu of saguaro flowers, lesser long-nosed bats foraged heavily on desert agave
(Agave deserti) flowers, a plant not typically used by lesser long-nosed bats (personal
communication with Scott Richardson, FWS, March 20, 2006). Similarly, there was a failure of
the agave bloom in southeastern Arizona in 2006, probably related to the ongoing drought. As a
result, lesser long-nosed bats left some roosts earlier than normal, and increased use of
hummingbird feeders by lesser long-nosed bats was observed in the Tucson area (personal
communication with Scott Richardson, FWS, January 11, 2008). Monitoring bats and their
forage during drought years is needed to better understand the effects of drought on this species.
We have produced numerous biological opinions on the lesser long-nosed bat since it was listed
as endangered in 1988, some of which anticipated incidental take. Incidental take has been in the
form or direct mortality and injury, harm, and harass and has typically been only for a small
number of individuals. Because incidental take of individual bats is difficult to detect, incidental
take has often been quantified in terms of loss of forage resources, decreases in numbers of bats
at roost sites, or increases in proposed action activities.
A few examples of more recent biological opinions that anticipated incidental take for lesser
long-nosed bats are summarized below. The 2007 biological opinion for the installation of one
600 kilowatt wind turbine and one 50KW mass megawatts wind machine on Fort Huachuca
included incidental take in the form of 10 bats caused by blade-strikes for the life (presumed
indefinite) of the proposed action. The 2005 biological opinion for implementation of the
Coronado National Forest Land and Resource Management Plan (U.S. Forest Service) included

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incidental take in the form of harm or harass. The amount of take for individual bats was not
quantified; instead take was to be considered exceeded if simultaneous August counts (at
transitory roosts in Arizona, New Mexico, and Sonora) drop below 66,923 lesser long-nosed bats
(the lowest number from 2001 – 2004 counts) for a period of two consecutive years as a result of
the action. The 2004 biological opinion for the Bureau of Land Management Arizona Statewide
Land Use Plan Amendment for Fire, Fuels, and Air Quality Management included incidental
take in the form of harassment. The amount of incidental take was quantified in terms of loss of
foraging resources, rather than loss of individual bats. The 2003 biological opinion for Marine
Corps Air Station (MCAS) – Yuma Activities on the BMGR included incidental take in the form
of direct mortality or injury (five bats every 10 years). Because take could not be monitored
directly, it was to be considered exceeded if nocturnal low-level helicopter flights in certain areas
on the BMGR increased significantly or if the numbers of bats in the Agua Dulce or Bluebird
Mine roosts decreased significantly and MCAS-Yuma activities were an important cause of the
decline. The 2002 biological opinion for Department of the Army Activities at and near Fort
Huachuca (Fort), Arizona anticipated incidental take in the form of direct mortality or injury (six
bats over the life of the project), harassment (20 bats per year), and harm (10 bats over the life of
the project).
ENVIRONMENTAL BASELINE
A. Action Area
The action area is defined as all areas to be affected directly or indirectly by the Federal action
and not merely the immediate area involved in the action (50 CFR §402.02). The FWS has
determined that the action area for the lesser long-nosed bat includes the areas directly impacted
by the installation of primary fence (including the fence and access roads) and an area around the
project defined by a circle with a radius of 36 miles (the maximum documented one-way
foraging distance of the lesser long-nosed bat). The action area represents only a small portion
of the lesser long-nosed bat’s range.
Management of the action area is largely by Federal agencies, as described in the “Action Area”
for Sonoran pronghorn. The action area for the lesser long-nosed bat also includes part of the
Tohono O’odham Nation (TON) and lands near the border in Sonora.
B. Terrain, Vegetation Communities, and Climate in the Action Area
A description of the region encompassing the action area has been previously provided (see
“Environmental Baseline”, part B. Terrain, Vegetation Communities, and Climate in the Action
Area” for the Sonoran pronghorn).
The project is near the Sonoyta and Puerto Blanco mountains. Suitable day and night roosting
potentially occur within the immediate project vicinity, however, these areas have not recently
been surveyed for lesser long-nosed bat roosts.
C. Status of the Lesser Long-Nosed Bat in the Action Area

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Based on the known foraging distances for lesser long-nosed bats, it is likely that this species
forages throughout portions of the OPCNM, CPNWR, TON, and BLM lands, where flowers and
fruit of saguaro, organ pipe, prickly pear, and agave are available.
Three large maternity roosts occur in the action area, including Bluebird Mine, Copper Mountain
Mine, and Pinacate Cave. Bluebird Mine, located along the eastern border of CPNWR in the
Growler Mountains, is over 15 miles northwest of the nearest border portion of the project site
and generally supports an estimated 3,000 lesser long-nosed bats at the peak of annual
occupancy (U.S. Fish and Wildlife Service 1997). The highest estimate of lesser long-nosed bats
using Bluebird Mine from 2001-2005 bats was 4,500. They abandoned the mine however in
2002, 2003, and 2005 due to disturbance from illegal activities. In 2004, the bats returned to the
mine after CPNWR staff placed a high steel fence around the mine to prevent disturbance. The
bats returned to the mine in 2005, however abandoned the site once again after the fence was
damaged, presumably by illegal immigrants or smugglers.
Copper Mountain Mine, located within the OPCNM, is about 15 miles north of the nearest
border portion of the project and supports approximately 25,000 bats at the peak of annual
occupancy (National Park Service 2002). The highest estimate of lesser long-nosed bats using
Copper Mountain Mine from 2001-2005 bats was 35,000.
The largest maternity roost in the project area is Pinacate Cave in northern Sonora, Mexico.
Approximately 40 miles south of the nearest border portion of project site, this roost is estimated
to support about 130,000 bats each year (U.S. Fish and Wildlife Service 1997). In May 2006,
approximately 200,000 lesser long-nosed bats were counted at the Pinacate Cave. However, in
2007, a significantly lower number of lesser long-nosed bats (83,000) were observed at this
roost.
Before they give birth, female bats probably occasionally move between the Bluebird and
Copper Mountain roosts, and it has been recommended that these two roosts be censused
simultaneously to avoid double-counting bats (U.S. Fish and Wildlife Service 1997).
Observations at Copper Mountain and Pinacate Cave indicate that they are occupied from midApril to early-to-mid-September (U.S. Fish and Wildlife Service 1997), although these roosts
reach their peak occupancy in late spring/early summer.
Though OPCNM and CPNWR monitor the Copper Mountain and Bluebird roosts annually to
determine the presence, abundance, and disturbance of lesser long-nosed bats, including
examining the roost year round for evidence of human entry, the rest of OPCNM and CPNWR
has not been well surveyed to determine the number of additional day and night roosts that might
exist in natural caves and/or mineshafts. A small roost or roosts is known to occur in the Agua
Dulce Mountains in the southeastern corner of the CPNWR, though the current status (i.e.,
whether lesser long-nosed bats are still using the site) of the roost is unknown. Smaller day
roosts are known in other mine tunnels, and are also suspected in other mines and natural rock
crevices and caves. Short-term night roosts are known in natural caves, under the eaves of
buildings, and inside several abandoned buildings associated with past ranching activities. It is
likely that there is within- and between-season interchange between these colonies, perhaps even
within and between nights (U. S. Fish and Wildlife Service 1997).

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Flowers and fruits of saguaro, organ pipe cactus, and cardon provide nearly all of the energy and
nutrients obtained by pregnant and lactating females roosting in the Sonoran Desert in the spring
and early summer (U.S. Fish and Wildlife Service 1997). Saguaro, which is common and
abundant throughout much of the BMGR, CPNWR, and OPCNM; and organ pipe cactus, which
is common at OPCNM and localized in the eastern portions of CPNWR and BMGR, and
portions of the TON, flower in May and fruit mature in June and July (Benson and Darrow
1982). Lesser long-nosed bats feed on both the nectar and fruits of these cacti. When cacti fruit
are scarce or unavailable in late July or early August, agave nectar may be the primary food
resource for lesser long-nosed bats in OPCNM, CPNWR, and TON. Agaves typically bolt or
flower and provide a nectar resource for foraging bats from about July into October. Desert
agave occurs in mountainous areas within the action area. As mentioned above under “Status of
the Species”, fires and drought may affect some lesser long-nosed bat foraging habitat within the
action area, though the extent is unknown.
A number of activities occur in the action area that could affect bats. For example, our 1997
biological opinion on the OPCNM General Management Plan, found that the proposed action
could result in incidental take of bats from recreation, specifically from unauthorized human
disturbance to the Copper Mountain maternity roost. Our 2003 biological and conference
opinion for the installation of the international boundary vehicle barrier on the OPCNM did not
find the action could result in incidental take, but found that the project would result in the
disturbance of 70 acres of potential lesser long-nosed bat foraging habitat, including the
destruction of up to 750 to 1000 saguaro and 80 to 100 organ pipe cacti (about 400 to 600 of
these were to be salvaged). Our 2006 biological opinion on the CBP - Office of the Border
Patrol’s installation of a permanent vehicle barrier (as well as access improvements,
construction/improvement of border roads, and associated maintenance and patrol activities)
along the border from the western end of the OPCNM barrier to Avenue C just east of San Luis,
Arizona, did not find the action could result in incidental take. It did find, however, that the
project would result in the direct disturbance of approximately 207 acres of potential lesser longnosed bat foraging habitat, including the destruction of up to 50 saguaros and 3 organ pipe cacti.
About 200 saguaros in the project corridor were to be avoided or salvaged.
High levels of undocumented immigrant activities and narcotics trafficking (see “Environmental
Baseline, part E. Threats” for the Sonoran pronghorn for further detail about undocumented
immigrant activity) and the associated damage resulting to the landscape from their activities, as
well the activities of law enforcement in pursuit of undocumented immigrants, is becoming an
increasing threat, not just to lesser long-nosed bats but to all wildlife of the region. As stated
earlier, much illegal traffic occurs through the Growler Mountains, and Bluebird Mine on
CPNWR in the Growlers was vandalized by suspected illegal immigrants in June 2002, which
resulted in at least four dead bats and abandonment of the roost. The bats returned to the mine in
2005; however, abandoned the site once again after the fence was damaged by illegal
immigrants. Both OPCNM and CPNWR are planning to implement additional protective
measures at Copper Mountain and Bluebird Mine, such as the possible construction of batfriendly gates at roost entrances to prevent illegal human entry. However, lesser long-nosed bats
are sensitive to bat gates and may not adapt readily to their use. Therefore, use of bat gates to
protect these roosts may not be a feasible alternative

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EFFECTS OF THE ACTION
Effects to Roosts
No known or suspected roost sites will be directly impacted by the proposed action. At its
closest point, the proposed project is approximately 15 miles from the Copper Mountain roost on
OPCNM and the Bluebird Mine roost on CPNWR, and will have no direct impact on these sites
or the Pinacate Cave roost site. Neither will the proposed action directly impact any potential
roosting habitat (mines, caves, etc.) on OPCNM.
The proposed action may have an indirect positive effect on lesser long-nosed bats using the
Copper Mountain roost if the fence decreases the amount of illegal pedestrian traffic in areas
directly north of the fence (the Copper Mountain roost site is located 15 miles north of the
proposed fence). Decreases in illegal pedestrian traffic near roost sites decrease the possibility of
illegal entry into these sites which can cause disturbance to bats (i.e., roost abandonment). The
proposed action, however, may adversely affect lesser long-nosed bats using the Bluebird Mine
roost if the fence results in the redirection of and subsequent increase in illegal pedestrian traffic
through the eastern portions of CPNWR. We anticipate the likelihood of this occurring is
relatively low.
Effects to Cross-Border Movements
The effects of fences on lesser long-nosed bat movement patterns are unknown. We do not
anticipate the fence will greatly impact cross-border movement of lesser long-nosed bats because
they are agile fliers and because the fence will not be installed along the entire border of
OPCNM. If the fence does impede their cross-border movements, the ability of lesser longnosed bats using the Pinacate roost to obtain adequate food resources will be diminished given
their heavy reliance on these resources in OPCNM.
Effects to Foraging Habitat
The proposed project will result in the disturbance of lesser long-nosed bat food plants
(approximately 206 to 266 saguaros and 295 to 397 organ pipe cacti5); however, as stated in the
“Description of the Proposed Action”, CBP will salvage (remove and replant outside the project
corridor) all columnar cacti less than three feet tall to the extent practicable (approximately 74
saguaros and 68 organ pipe cacti 5 ) and will attempt to salvage all columnar cacti between three
and six feet tall (41 saguaro and 55 organ pipe cacti5) that face danger of destruction within the
project corridor as determined by the biological monitor and that have been identified using
GPS-technology (either by GSRC or OPCNM). Because saguaros and organ pipe cacti less than
6 feet tall generally do not flower, the salvaged cacti, once replanted, will not be available as a
forage resource for lesser long-nosed bats until they reach the size at which they flower.
Construction activities associated with the proposed project will likely destroy approximately 91
to 126 saguaros and 172 to 285 organ pipe cacti on the OPCNM; approximately 115 to 140
saguaros and 112 to 123 organ pipe within the project corridor will be salvaged. Seedlings that

5

During a recent survey (February 2008), OPCNM staff counted a total of 140 salvageable saguaros and 112
salvageable organ pipe cacti and 126 non-salvageable saguaros and 285 non-salvageable. These numbers differ
from those provided by GSRC; however, regardless of the exact number, all saguaros and organ pipe determined to
be salvageable within the project footprint will be salvaged.

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may have been missed during the surveys 6 will likely be destroyed by project activities.
Additionally, the roots and rooting areas of plants adjacent to the project corridor might also be
damaged, which may affect plant vigor and cause increased plant mortality.
According to BP, the proposed project will result in the permanent disturbance of about 45 acres.
Of this, about 17 acres was previously disturbed by the installation of PVBs; however, about 28
acres of potential lesser long-nosed bat foraging habitat adjacent to the international border will
be newly disturbed. The 45 acres of disturbed ground will be susceptible to colonization by
invasive non-native plants such as buffelgrass, Sahara mustard, and Eruca vesicaria. Non-native
species may prevent the recruitment of lesser long-nosed bat forage species (columnar cacti and
agaves) and may also carry fire that could also impact lesser long-nosed bat forage species.
Most Sonoran Desert trees, shrubs, and cacti are very fire intolerant. For example, fires at
Saguaro National Park resulted in greater than 20 percent mortality of mature saguaros
(Schwalbe et al. 2000).
In addition to areas directly disturbed by the project, we anticipate some, unquantifiable amount
of potential lesser long-nosed bat foraging habitat will be affected by altered hydrology and
increased erosion and sedimentation caused by the fence and associated road. Though the Final
EA says that the fence and road will be designed and constructed in a way that would not alter
drainage patterns or cause increased downstream erosion and sedimentation, we expect some
effects to hydrological function based on the effects of the OPCNM PVB. According to the
Research and Endangered Species Coordinator at OPCNM, after significant rainfall events,
debris becomes lodged on the OPNCM PVBs (six inch-wide posts on five-foot centers), which
creates a dam that causes water to pool upstream (up to 100+ feet) and laterally (up to 300+
feet)(electronic mail from Tim Tibbits, October 4, 2007). We anticipate the fence and road will
cause at least some changes in hydrology, as well as increased erosion and sedimentation.
Destruction of and damage to lesser long-nosed bat forage plants and disturbance of potential bat
foraging habitat will reduce food available to the lesser long-nosed bat; this will likely adversely
affect bats, especially during drought periods when forage availability is already impaired. It is
difficult to evaluate the significance of the loss of foraging habitat; however, this loss is small
compared to the large amount of potentially suitable foraging habitat available to the lesser longnosed bat throughout the action area. However, it is still extremely important that effects to
forage resources are minimized.
The proposed project may result in fewer disturbances to lesser long-nosed bat foraging habitat
directly north of the fence if the fence decreases the amount of illegal pedestrian and pursuant
law enforcement traffic in these areas. Construction of the fence, if it redirects illegal pedestrian
and pursuant law enforcement activities to the east and west of the fence, however, may result in
greater disturbance of lesser long-nosed bat foraging habitat in these areas. Trails and other soil
disturbance can increase erosion, promote the spread of invasive plant species, and increase the
potential for fires, which can adversely affect lesser long-nosed bat food resources. Off-road
vehicle travel may damage the shallow root systems of large columnar cacti, causing loss of
6

Gulf South Research Corporation conducted surveys in August 2007 by walking, with 30 feet between two
surveyors, the project corridor and recording the species and location of each columnar cactus seen.

Mr. George Hutchinson

40

vigor or death, and result in destruction of numerous columnar cacti, and can be assumed to
destroy large numbers of seedlings. Also, off-road travel can cause changes in surface hydrology
(from channelization of water in entrenched vehicle track prisms), which can adversely affect
vegetation, including lesser long-nosed bat forage species.
Though nighttime construction is not anticipated, if it occurs within bat foraging habitat, bat
foraging behavior may be temporarily affected. Because bats are nocturnal, we do not anticipate
that daytime construction and maintenance activities will affect bat foraging behavior.
Conservation measures
Environmental design measures incorporated into the project, such as implementing erosion
control techniques and constructing the fence in arroyos in a way that ensures proper conveyance
of floodwater, will help minimize project impacts to lesser long-nosed bat foraging habitat.
Additionally, CBP’s commitment to salvage, replant, and monitor the success of 238 columnar
cacti; restore 84 acres within OPNCM, and control non-native plants within the project footprint,
will help offset project impacts to lesser long-nosed bats.
CUMULATIVE EFFECTS
Most lands within the action area are managed by Federal agencies; thus, most activities that
could potentially affect bats are Federal activities that are subject to section 7 consultation. The
effects of these Federal activities are not considered cumulative effects. However, a portion of
the action area also occurs on the TOIR, on private lands in the U.S., and in Mexico. Residential
and commercial development, farming, livestock grazing, surface mining and other activities
occur on these lands and are expected to continue into the foreseeable future. These actions, the
effects of which are considered cumulative, may result in small-scale loss or degradation of
lesser long-nosed bat foraging habitat, and potential disturbance of roosts. Illegal
immigrant/smuggler activities, described above under “Cumulative Effects” for pronghorn, can
result in loss or degradation of potential lesser long-nosed bat foraging habitat (impacts to
foraging habitat have not been quantified however) and disturbance to and abandonment of
roosts, as has been documented at the Bluebird Mine roost site. Though immigrant/smuggler
activity has been high in recent years, it has declined recently, likely due to increased law
enforcement presence (see Cumulative Effects for the pronghorn). In spite of these activities,
lesser long-nose bat populations appear to be increasing or stable at many roost sites within and
outside the action area.
CONCLUSION
After reviewing the current status of the lesser long-nosed bat, the environmental baseline for the
action area, the effects of the proposed activities associated with the Lukeville fence project, and
the cumulative effects, it is our biological opinion that the proposed action is not likely to
jeopardize the continued existence of the lesser long-nosed bat. No critical habitat has been
designated for this species, therefore, none will be affected. Our conclusion is based on the
following:

Mr. George Hutchinson

41

1. Lesser long-nosed bat populations appear to be increasing or stable at many roost sites in
Arizona and Mexico.
2. The project will not directly affect any known bat roosts in the action area (Bluebird
Mine, Copper Mountain Mine, and Pinacate Cave).
3. The project may increase the possibility of disturbance to bats at the Bluebird Mine roost
site if it results in the redirection of and subsequent increase in illegal pedestrian traffic
through the eastern portions of CPNWR; however, we anticipate the likelihood of this
occurring is relatively low.
4. The project will result in direct loss of 28 acres of lesser long-nosed bat foraging habitat,
but disturbance to and loss of foraging habitat and forage plants will be minimized
through environmental design measures, such as implementing erosion control, and offset
through conservation measures, such as the salvage of columnar cacti and habitat
restoration. Specifically, CBP will salvage (remove and replant outside the project
corridor) all columnar cacti less than three feet tall to the extent practicable and will
attempt to salvage all columnar cacti between three and six feet tall (an estimated 238
saguaro and organ pipe cacti will be salvaged) that face danger of destruction within the
project corridor as determined by the biological monitor and that have been identified
using GPS-technology (either by GSRC or OPCNM). Additionally, CBP will fund the
restoration of 84 acres within OPCNM.
The conclusions of this biological opinion are based on full implementation of the project as
described in the “Description of the Proposed Action” section of this document, including any
conservation measures that were incorporated into the project design.
INCIDENTAL TAKE STATEMENT
Section 9 of the ESA and Federal regulation pursuant to section 4(d) of the ESA prohibit the take
of endangered and threatened species, respectively, without special exemption. “Take” is defined
as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or to attempt to
engage in any such conduct. “Harm” is defined to include significant habitat modification or
degradation that results in death or injury to listed species by significantly impairing essential
behavioral patterns, including breeding, feeding, or sheltering (50 CFR 17.3). “Harass” is
defined as intentional or negligent actions that create the likelihood of injury to listed species to
such an extent as to significantly disrupt normal behavior patterns which include, but are not
limited to, breeding, feeding or sheltering (50 CFR 17.3). “Incidental take” is defined as take
that is incidental to, and not the purpose of, the carrying out of an otherwise lawful activity.
Under the terms of section 7(b)(4) and section 7(o)(2), taking that is incidental to and not
intended as part of the agency action is not considered to be prohibited taking under the ESA
provided that such taking is in compliance with the terms and conditions of this incidental take
statement.

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42

AMOUNT OR EXTENT OF TAKE ANTICIPATED
We do not anticipate the proposed action will result in incidental take of lesser long-nosed bat for
the following reasons:
1. The project will not directly affect any known bat roosts.
2. Impacts to bat foraging habitat and plants will be minimized and offset.
DISPOSITION OF DEAD OR INJURED LISTED SPECIES
Upon locating a dead, injured, or sick listed species initial notification must be made to the
FWS's Law Enforcement Office, 2450 West Broadway Road, Suite 113, Mesa, Arizona, 85202,
telephone: [phone]), made within five calendar days and include the date, time, and
location of the animal, a photograph if possible, and any other pertinent information. The
notification shall be sent to the Law Enforcement Office with a copy to this office. Care must be
taken in handling sick or injured animals to ensure effective treatment and care and in handling
dead specimens to preserve the biological material in the best possible state.
CONSERVATION RECOMMENDATIONS
Section 7(a)(1) of the ESA directs Federal agencies to utilize their authorities to further the
purposes of the ESA by carrying out conservation programs for the benefit of endangered and
threatened species. Conservation recommendations are discretionary agency activities to
minimize or avoid effects of a proposed action on listed species or critical habitat, to help
implement recovery plans, or to develop information. We recommend implementing the
following actions:
1. In conjunction with OPCNM, CPNWR, BMGR, BLM, and TON facilitate restoration
(i.e., re-contour entrenched areas, ensure the establishment of native vegetation, etc.) of
areas degraded by off-route travel (by illegal immigrants/smugglers and OBP) within the
action area (in addition to the areas that will be restored as part of the proposed action).
2. Monitor or provide funding to land managers to monitor future ecological conditions in
the action area, including the overall success of active and passive restoration (i.e., the
degree to which native vegetation becomes reestablished on illegal routes, the degree to
which non-native invasive plants have decreased or increased, etc.).
3. Assist agencies in the control of non-native plants that may alter fire frequencies and
intensities within OPCNM, CPNWR, BMGR, BLM, and TON, and in developing
methods for controlling these species (lesser long-nosed bat Recovery Plan task 2).
4. Provide annual financial assistance (at least until illegal CPNWR immigrant/smuggler
entry into southwestern Arizona is significantly reduced) to OPCNM, CPNWR, BMGR,
BLM, and TON to monitor the effects of illegal immigrants/smugglers on lesser long-

Mr. George Hutchinson

43

nosed bat roosts and foraging habitat and to restore habitat and implement protective
measures for lesser long-nosed bats, such as fencing around roost sites.
5. Provide annual financial assistance (at least until illegal immigrant/smuggler entry into
southwestern Arizona is significantly reduced) to OPCNM, CPNWR, BMGR, and BLM
to monitor the effects of illegal immigrants/smugglers on pronghorn and their habitat,
particularly near forage enhancement plots, water sites, and the semi-captive breeding
pen, and to restore habitat and implement recovery actions for the Sonoran pronghorn.
6. Provide ongoing financial support to agencies to implement the Sonoran pronghorn and
lesser long-nosed bat recovery plans, as appropriate.
7. Tucson and Yuma Sector offices should each have a full-time biologist or environmental
specialist to assist OBP compliance with ESA, NEPA, and other environmental
requirements; to provide environmental training to agents; and to coordinate with
agencies regarding environmental issues.
In order for us to be kept informed of actions minimizing or avoiding adverse effects or
benefiting listed species or their habitats, we request notification of the implementation of any
conservation recommendations.
REINITIATION - CLOSING STATEMENT
This concludes formal consultation on the action outlined in this biological opinion. As provided
in 50 CFR § 402.16, reinitiation of formal consultation is required where discretionary Federal
agency involvement or control over the action has been retained (or is authorized by law) and if:
(1) the amount or extent of incidental take is exceeded; (2) new information reveals effects of the
agency action that may affect listed species or critical habitat in a manner that causes an effect to
the listed species or critical habitat in a manner or to an extent not considered in this opinion; (3)
the agency action is subsequently modified in a manner that causes an effect to a listed species or
critical habitat that was not considered in this opinion; or (4) a new species is listed or critical
habitat designated that may be affected by the action. In instances where the amount or extent of
incidental take is exceeded, any operations causing such take must cease pending reinitiation.
We appreciate CBP’s efforts to identify, minimize, and offset effects to listed species from the
project. For further information, please contact Erin Fernandez (x238) or Jim Rorabaugh (x230)
of our Tucson Suboffice at [phone]. Please refer to the consultation number 224102008-F-0011 in future correspondence concerning this project.
Sincerely,

Steven L. Spangle
Field Supervisor

Mr. George Hutchinson
cc: Assistant Field Supervisor, Fish and Wildlife Service, Tucson, AZ
Superintendent, Organ Pipe Cactus National Monument, Ajo, AZ
Refuge Manager, Cabeza Prieta National Wildlife Refuge, Ajo, AZ
Director Construction and Support Office, Army Corps of Engineers, Ft. Worth, TX (Attn:
Charles McGregor)
Chief, Habitat Branch, Arizona Game and Fish Department, Phoenix, AZ
Regional Supervisor, Arizona Game and Fish Department, Tucson, AZ
Regional Supervisor, Arizona Game and Fish Department, Yuma, AZ
Gulf South Research Corporation, Baton Rouge, LA (Attn: Chris Ingram)
Chairperson, Tohono O’Odham Nation, Sells, AZ

44

Mr. George Hutchinson

45
REFERENCES CITED

Alford, E.J., and J.H. Brock. 2002. Effects of fire on Sonoran Desert plant communities. Page 20
in W.L. Halvorson and B.S. Gebow (eds.), Creative Cooperation in Resource Management:
Fourth Conference on Research and Management in the Southwestern Deserts, extended
abstracts. USGS Sonoran Desert Field Station, University of Arizona, Tucson, AZ.
Arizona Game and Fish Department (AGFD). 2005. Comments submitted 5/3/05 and 5/12/05, in
response to Federal Register Notice of Review (70 FR 5460) for the lesser long-nosed bat
(Leptonycteris curasoae yerbabuenae).
Bright, J.L., and J.J. Hervert. 2005. Adult and fawn mortality of Sonoran pronghorn. Wildlife
Society Bulletin 33(1):43-50.
Bright, J.L., J.J. Hervert, L.A. Piest, R.S. Henry, and M. T. Brown. 1999. Sonoran pronghorn
1998 aerial survey summary. Nongame and Endangered Wildlife Program Technical
Report No. 152. Arizona Game and Fish Department, Phoenix, AZ.
Bright, J.L., J.J. Hervert, and M.T. Brown. 2001. Sonoran pronghorn 2000 aerial survey
summary. Technical Report No. 180. Arizona Game and Fish Department, Phoenix, AZ.
Brown, D.E. 1982. Biotic communities of the American Southwest – United States and Mexico.
Desert Plants 4(1-4):1-342.
Brown, D.E., and R.A. Minnich. 1986. Fire and changes in creosote bush scrub of the western
Sonoran Desert, California. American Midland Naturalist 116(2):411-422.
Carr, J.N.. 1974. Complete report-Endangered species investigation. Sonoran pronghorn.
Arizona Game and Fish Department, Phoenix, AZ.
Cherkovich, G.M., and S.K. Tatoyan. 1973. Heart rate (radiotelemetric registration) in macaques
and baboons according to dominant-submissive rank in a group. Folia Primatol 20:265-273.
Cockrum, E.L., and Y. Petryszyn. 1991. The lesser long-nosed bat. Leptonycteris: An
endangered species in the Southwest? Texas Tech Univ., Occas. Pap. Mus., Number 142.
Dalton, V.M., D.C. Dalton, and S.L. Schmidt. 1994. Roosting and foraging use of a proposed
military training site by the long-nosed bat, Leptonycteris curasoae. Report to the Luke Air
Force Natural Resources Program, Contract Nos. DACA65-94-M-0831 and DACA65-94M-0753. 34pp.

Mr. George Hutchinson

46

Defenders of Wildlife. 1998. Population viability analysis workshop for the endangered Sonoran
pronghorn (Antilocapra americana sonoriensis) in the United States. Defenders of Wildlife
unpublished manuscript, Washington, D.C.
deVos, J.C., and W.H. Miller. 2005. Habitat use and survival of Sonoran pronghorn in years with
above-average rainfall. Wildlife Society Bulletin 33(1):35-42.
Ehrlich, P.R., and J. Roughgarden. 1987. The Science of Ecology. MacMillan Publishing Co.,
New York, N.Y.
Flat-tailed Horned Lizard Interagency Coordinating Committee. 2003. Flat-tailed horned lizard
rangewide management strategy, 2003. 78 pp. plus appendices.
Fox, L.M., P.R. Krausman, M.L. Morrison, and R.M. Kattnig. 2000. Water and nutrient content
of forage in Sonoran pronghorn habitat, Arizona. California Fish and Game 86(4): 216-232.
Geist, V. 1971. A behavioral approach to the management of wild ungulates. In E. Duffey and
A.S. Watts, eds., The Scientific Management of Animal and Plant Communities for
Conservation. Symposium of the British Ecological Society No. 11. Blackwell Science
Publications, Oxford, U.K.
Gentry, H.S. 1982. Agaves of continental North America. Pages 443-447 and 538-545,
University of Arizona Press, Tucson, Arizona.
Gerstenzang, J. 2006. Bush visits border, urges Senate action. Los Angeles Times, May 19,
2006.
Gilpin, M.E. and M.E. Soulé. 1986. Minimum viable populations: processes of extinction. In
M.E. Soulé, ed., Conservation Biology: The science of scarcity and diversity. Sinauer
Associates, Sunderland, MA.
Goldman, E.A. 1945. A new pronghorn from Sonora. Proceedings of the Biological Society,
Washington 58:3-4.
Harlow, H.J., E.T. Thorn, E.S. Hilliams, E. L. Belden, and W.A. Gern. 1987. Cardiac frequency:
a potential predictor of blood cortisol levels during acute and chronic stress exposure in
Rocky Mountain bighorn sheep (Ovis canadensis canadensis). Canadian Journal of
Zoology 65:2028-2034.
Hecht, A. and P.R. Nickerson. 1999. The need for predator management in conservation of some
vulnerable species. Endangered Species Update 16:114-118.

Mr. George Hutchinson

47

Hervert, J.J., J.L. Bright, M.T. Brown, L.A. Piest, and R.S. Henry. 2000. Sonoran pronghorn
population monitoring: 1994-1998. Nongame and Endangered Wildlife Program Technical
Report No. 162. Arizona Game and Fish Department, Phoenix, AZ.
Hervert, J.J. J.L. Bright, R.S. Henry, L.A. Piest, and M.T. Brown. 2005. Home-range and
habitat-use patterns of Sonoran pronghorn in Arizona. Wildlife Society Bulletin 33(1):8-15.
Hervert, J.J., L.A. Piest, R.S. Henry, and M.T. Brown. 1997a. Sonoran pronghorn 1996 aerial
survey summary. Nongame and Endangered Wildlife Program Technical Report No. 124.
Arizona Game and Fish Department, Phoenix, AZ.
Hervert, J.J., L.A. Piest, W. Ballard, R.S. Henry, M.T. Brown, and S. Boe. 1997b. Sonoran
pronghorn population monitoring: progress report. Nongame and Endange red Wildlife
Program Technical Report No. 126. Arizona Game and Fish Department, Phoenix, AZ.
Hoffmeister, D.F. 1986. Mammals of Arizona. University of Arizona Press, Tucson.
Horner, M.A., T.H. Fleming, and M.D. Tuttle. 1990. Foraging and movement patterns of a nectar
feeding bat: Leptonycteris curasoae. Bat Research News 31:81.
Hosack, D.A., P.S. Miller, J.J. Hervert, and R.C. Lacy. A population viability analysis for the
endangered Sonoran pronghorn, Antilocapra americana sonoriensis. Mammalia 66(2):207229.
Hughes, K.S., and N.S. Smith. 1990. Sonoran pronghorn use of habitat in Southwest Arizona.
Report to Cabeza Prieta National Wildlife Refuge, Ajo, AZ.
Intergovernmental Panel on Climate Change. 2007. Summary for policymakers of the synthesis
report of the IPCC fourth assessment report. Draft copy, 16 November 2007.
International Boundary Commission. 1936. Investigations Relating to the Establishment of a
Federal Zone Along the International Boundary United States and Mexico From the Rio
Grande to the Pacific Ocean. Report of the American Commissioner. El Paso, Texas.
Johnson, B.K., F.G. Lindzey, and R.J. Guenzel. 1991. Use of aerial line transect surveys to
estimate pronghorn populations in Wyoming. Wildlife Society Bulletin 19:315-321.
Kindschy, R.R., C. Sundstrom, and J.D. Yoakum 1982. Wildlife habitats in managed rangelands
- the Great Basin of southeastern Oregon: pronghorn. General Technical Report PNW-145.
U.S. Department of Agriculture, Northwest Forest and Range Experimental Station,
Portland, OR.
Klein, K. 2000. Mass smugglings of immigrants on the increase. March 13, Desert Sun, Palm
Springs, www.thedesertsun.online.com.

Mr. George Hutchinson

48

Krausman, P.R., L.K. Harris, C.L. Blasch, K.K.G. Koenen, and J. Francine. 2004. Effects of
military operations on behavior and hearing of endangered Sonoran pronghorn. Wildlife
Monographs 157:1-41.
Krausman, P.R., L.K. Harris, S.H. Haas, K.K.G. Koenen, P. Devers, D. Bunting, and M. Barb.
2005a. Sonoran pronghorn habitat us on landscapes disturbed by military activities.
Wildlife Society Bulletin 33(1):16-33.
Krausman, P.R., J.R. Morgart, L.K. Harris, C.S. O’Brian, J.W. Cain III, and S.S. Rosenstock.
2005. Introduction: management for the survival of Sonoran pronghorn in the United
States. Wildlife Society Bulletin 33(1):5-7.
Krausman, P.R., L.K. Harris, and J. Francine. 2001. Long-term study of the noise effects of
military overflights on the Sonoran pronghorn, Barry M. Goldwater Range, Luke Air Force
Base, Arizona. U.S. Air Force Contract F41624-98-C-8020-P00003.
Leftwich, T.J., and C.D. Simpson. 1978. The impact of domestic livestock and farming on Texas
pronghorn. Pronghorn Antelope Workshop Proceedings 8:307-320.
Marine Corps Air Station-Yuma. 2001. Yuma Training Range Complex draft supplemental
environmental impact statement. U.S. Department of Defense, Marine Corps Air Station,
Yuma, AZ.
Mearns, E.A. 1907. Mammals of the Mexican boundary of the United States, Part 1. Bulletin of
the U.S. National Museum 56:XVT530.
Milstead, B, and B. Barns. 2002. Life on the border: monitoring the effects of border-crossing
and law enforcement on natural resources. W.L. Halvorson and B.S. Gebow, eds., Meeting
resource management information needs: fourth conference on research and resource
management in the southwestern deserts, extended abstracts. USGS Sonoran Desert Field
Station, University of Arizona, Tucson: 87-88.
Miskus, D. 2006. U.S. drought monitor. U.S. Department of Agriculture, National Drought
Mitigation Center. http://drought.unl.edu/dm/monitor.html.
Moen, A.N., M.A. DellaFera, A.L. Hiller, and B.A. Buxton. 1978. Heart rates of white-tailed
deer fawns in response to recorded wolf howls. Canadian Journal of Zoology 56:12071210.
Monson, G. 1968. The desert pronghorn. In Desert Bighorn Council Transactions. Las Vegas,
NV.

Mr. George Hutchinson

49

Morgart, J.R., J.J. Hervert, P.R. Krausman, J.L. Bright, and R.S. Henry. 2005. Sonoran
pronghorn use of anthropogenic and natural waters. Wildlife Society Bulletin
33(1):51-60.
National Park Service. 2002. Threatened, endangered and sensitive species: Annual
summary of activities. Resources Management Division, Organ Pipe Cactus
National Monument, Ajo, Arizona.
Nelson, F.W. 1925. Status of the pronghorn antelope, 1922-1924. U.S. Department of
Agriculture Bulletin No. 1346.
Nowak, R.M., and J.L. Paradiso. 1983. Walker’s mammals of the world. 4th Ed. Vol. II.
Johns Hopkins University. Press, Baltimore, MD.
Officer, J.E. 1993. Kino and agriculture in the Pimeria Alta. Journal of Arizona History
34:287-306.
Organ Pipe Cactus National Monument. 2001. Draft supplemental environmental impact
statement, re-analysis of cumulative impacts on the Sonoran pronghorn. Organ Pipe
Cactus National Monument, Ajo, AZ.
Paradiso, J.L., and R.M. Nowak. 1971. Taxonomic status of the Sonoran pronghorn.
Journal of Mammalogy 52(4):855-858.
Pinkava, D.J. 1999. Cactaceae Cactus Family, Part Three. In: Vascular Plants of Arizona:
Cactaceae - Cylindropuntia. Journal of the Arizona- Nevada Academy of Science
32(1):32-47.
Richter-Dyn, N., and N.S. Goel. 1972. On the extinction of a colonizing species.
Theoretical Population Biology 3:406-433.
Rowlands, P.G. 2000. Low temperature and other climatic trends at Organ Pipe Cactus
National Monument. In W.L. Halvorson and B.S. Gebow, eds., Creative
Cooperation in Resource Management, extended abstracts. U.S. Geological Survey,
Western Ecological Research Center, Sonoran Desert Field Station, University of
Arizona, Tucson, AZ.

Mr. George Hutchinson

50

Rutman, S. 1997. Dirt is not cheap: livestock grazing and a legacy of accelerated soil
erosion on Organ Pipe Cactus National Monument, Arizona. In J. M. Feller and D.
S. Strouse, eds., Environmental, economic, and legal issues related to rangeland
water developments. The Center for the Study of Law, Science and Technology,
Arizona State University, Tempe, AZ.
Samuel, M.D., and K.H. Pollock. 1981. Correction of visibility bias in aerial surveys
where animals occur in groups. Journal of Wildlife Management 45(4):993-997.
Schwalbe, C.R., T.C. Esque, P.J. Anning, and W.L. Halvorson. 2000. Exotic grasses,
long-lived species, and managing desert landscapes: a case history at Saguaro
National Park. Page 87 in W.L. Halvorson and B.S. Gebow (eds), Creative
Cooperation in Resource Management: Third Conference on Research and
Management in the Southwestern Deserts, extended abstracts. USGS Sonoran
Desert Field Station, University of Arizona, Tucson, AZ.
Seager, R., M. Ting, T. Held, Y. Kushnir, J. Lu, G. Vecchi, H. Huang, N. Harrnik, A.
Leetmaa, N. Lau, C. Li, J. Velez, and N. Naik. 2007. Model projections of an
imminent transition to a more arid climate in southwestern North America. Science
316:1181-1184.
Segee, B.P., and J.L. Neeley. 2006. On the line, the impacts of immigration policy on
wildlife and habitat in the Arizona borderlands. Defenders of Wildlife, Washington,
D.C. 40 p.
Sheridan, T.E. 2000. Human ecology of the Sonoran Desert. In S.J. Phillips and P.W.
Comus, eds., A natural history of the Sonoran Desert. Arizona-Sonora Desert
Museum Press, Tucson, AZ.
Sidner, R. 2000. Report of activities under permit TE-821369-0. Report to the US Fish
and Wildlife Service, Albuquerque, New Mexico.
Sidner, R. 2005. Fifteen years of monitoring the endangered lesser long-nosed bat
(Leptonycteris curasoae) and other bat species on the Fort Huachuca Military
Installation, Cochise County, Arizona. June-November 2004. EEC Project Report to
Commander, U.S. Army Garrison, Fort Huachuca, AZ. 105 pp.
Sidner, R. and F. Houser. 1990. Lunarphilia in nectar-feeding bats in Arizona. Bat
Research News 31(4):15.
Thompson, R.D., C.V. Grant, E.W. Pearson, and G.W. Corner. 1968. Cardiac response of
starlings to sound: effects of lighting and grouping. American Journal of Physiology
214:41-44.

Mr. George Hutchinson

51

Tibbitts, Tim. 2005. Annual report for threatened and endangered species permit No.
TE19458-1. Resources Management Division, Organ Pipe Cactus National
Monument, Ajo, Arizona.
U.S. Fish and Wildlife Service. 1982. Sonoran pronghorn recovery plan. U.S. Fish and
Wildlife Service, Region 2, Albuquerque, NM.
U.S. Fish and Wildlife Service. 1988. Endangered and threatened wildlife and plants;
determination of endangered status for two long-nosed bats. Federal Register
53(190):38456-3860.
U.S. Fish and Wildlife Service. 1997. Lesser long-nosed bat recovery plan. Albuquerque,
New Mexico. 49pp.
U.S. Fish and Wildlife Service. 1998. Final revised Sonoran pronghorn recovery plan.
U.S. Fish and Wildlife Service, Albuquerque, NM.
U.S. Fish and Wildlife Service. 2001. Recovery criteria and estimates of time for
recovery actions for the Sonoran pronghorn: a supplement and amendment to the
1998 final revised Sonoran pronghorn recovery plan. U.S. Fish and Wildlife
Service, Albuquerque, NM.
U.S. Customs and Border Protection. 2005. Preliminary draft biological assessment
permanent vehicle barriers, Barry M. Goldwater Range and Cabeza Prieta National
Wildlife Refuge, Yuma and Pima Counties, AZ. U.S. Customs and Border
Protection, Washington, D.C.
Wolf, S. and D. Dalton. 2005. Comments submitted 4/20/05 and 5/2/05, in response to
Federal Register Notice of Review (70 FR 5460) for the lesser long-nosed bat
(Leptonycteris curasoae yerbabuenae).
Workman, G.D., T.D. Bunch, J.W. Call, F.C. Evans, L.S. Neilson, and E.M. Rawlings.
1992. Sonic boom and other disturbance impacts on pronghorn antelope
(Antilocapra americana). Report to the U.S. Air Force, Hill Air Force Base, UT.
Wright, R.L,. and J.C. deVos. 1986. Final report on Sonoran pronghorn status in Arizona.
Contract No. F0260483MS143, Arizona Game and Fish Department, Phoenix, AZ
Yoakum, J.D., B.W. O’Gara, and V.W. Howard, Jr. 1996. Pronghorn on western
rangelands. In P.R. Krausman, ed., Rangeland wildlife. The Society for Range
Management, Denver, CO.
Weiss, J.L., and J.T. Overpeck. 2005. Is the Sonoran Desert losing its cool? Global
Change Biology 11:2065-2077.

Mr. George Hutchinson

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TABLES AND FIGURES

Table 1. A summary of population estimates from literature and field surveys for
Sonoran pronghorn in the U.S.
Date

Population estimate
(95 percent CIa)

Source

1925

105

Nelson 1925

1941b

60

Nicol 1941

1957

<1,000

Halloran 1957

1968

50

Monson 1968

1968-1974

50 - 150

Carr 1974

1981

100 - 150

Arizona Game and Fish Department 1981

1984

85 - 100

Arizona Game and Fish Department 1986

1992

179 (145-234)

Bright et al. 1999

1994

282 (205-489)

Bright et al. 1999

1996

130 (114-154)

Bright et al. 1999

1998

142 (125-167)

Bright et al. 1999

2000

99 (69-392)

Bright et al. 2001

2002

21 (18-33)

Bright and Hervert 2003

2004

58 (40-175)

Bright and Hervert 2005

2006

68 (52-116)

Unpublished data

a

Confidence interval; there is only a 5 percent chance that the population total falls
outside of this range.
b
Population estimate for southwestern Arizona, excluding Organ Pipe Cactus National
Monument.

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53

Table 2. Comparison of U.S. Sonoran pronghorn population surveys, 1992-2006.
Pronghorn observed

Population estimates

Date

Total
observed

Dec 92

99

121

246 (103-584)

---

179 (145-234)

Mar 94

100

109

184 (100-334)

---

282 (205-489)

Dec 96

71

82 (95b)

216 (82-579)

162 (4-324)

130 (114-154)

Dec 98

74

86 (98b)

---

172 (23-321)

142 (125-167)

Dec 00

67

69b

N/A

N/A

99 (69-392)

Dec 02

18

18

N/A

N/A

21 (18-33)c

Dec 04

39

51

N/A

N/A

58

Dec 06
a

On
transect

Density estimate
using DISTANCE
(95 percent CIa)

Lincoln-Peterson
(95 percent CI)

Sightability
model (95
percent CI)

51

59

N/A

N/A

68

Confidence interval; there is only a 5 percent chance that the population total falls
outside of this range.
b
Includes animals missed on survey, but located using radio telemetry.
C
Jill Bright, Arizona Game and Fish Department, pers. comm. 2003

Mr. George Hutchinson

54

Figure 1. Proposed Lukeville Primary Fence Project corridor (Final EA, November 2007)

Mr. George Hutchinson
Figure 2. Historic range of Sonoran pronghorn in the Unites States and Mexico.

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Mr. George Hutchinson
Figure 3. Current Sonoran pronghorn distribution in the United State: Records from
1994-2001.

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